April 05, 2018
The WaMS update released today by DBHDS is problematic for a variety of reasons, not the least of which is that it appears to not accurately capture the agreement made between the CSBs and DBHDS on the scope of the data transfer.
In addition, the general description of the purported “value” includes a presumption that WaMS will become the primary repository for ISPs. For many reason, including the ultimate responsibility of the provider to create and maintain the records necessary to support good clinical practice and “sufficient to document fully and accurately the nature, scope and details of the services provided,” WaMS will not meet the need. WaMS will retain records for only six years, not meeting the requirement to retain records for at least six years from the last date of service or after a minor has reached the age of 18!
Some of the content of this memo is what we had hoped to hear and, perhaps discuss, on our last Member Call. It is unfortunate that the DBHDS representative was not able to join us; he will be available on the April call on the 20th.
A copy of the memo is attached here
– stay tuned for further developments!