As someone who has worked in behavioral health care for my entire adult life in roles ranging from day staff to VP of operations, I’ve noticed a common need in our industry. This need is a focus on compliance and quality assurance, which is also a core part of emergency management and risk mitigation. One cannot say they provide quality care if they don’t first have a system in place that protects clients and staff. This system must encompass everything from preparedness for environmental disasters to ensuring that protected health information isn’t disseminated incorrectly.
I know that several of us in the behavioral health care industry are longing for the day that we are treated on equal terms with medical care. For us to do that we must take compliance and quality assurance as seriously as the medical field is required to. Let’s face it: Regulatory requirements for non-hospital based behavioral health is neither as stringent nor as formalized as it is for medical providers.
I think one of the major reasons for this is, for many of us, our graduate level education did not include things like working with insurance companies, Medicaid and Medicare requirements, HIPAA, and risk management. I know that when I was in school, we weren’t taught about any of these things. I believe one of the consequences of this is that, when practitioners get independently licensed and open up their own private practices, they are extremely vulnerable to risk because of their lack of understanding of state and federal requirements.
For example, not one of the strictly outpatient clients we have worked with has ever conducted a HIPAA electronic risk analysis which is a requirement for entities and businesses that handle protected health information. From the Department of Health and Human Services website
“RISK ANALYSIS (Required). Conduct an accurate and thorough assessment of the potential risks and vulnerabilities to the confidentiality, integrity, and availability of electronic protected health information held by the [organization].”
This becomes one of many instances where “you don’t know what you don’t know,” but ignorance of the requirements does not protect clients or businesses if there is a breach of health information, for-cause audit, or other event resulting in increased regulatory oversight.
So, what can we do as behavioral health practitioners? Well, first we can make a commitment to ensure our practice meets all applicable regulatory requirements. Second, if we are unsure then we need to ask for help from those who have expertise in these areas.
This leads me to a conversation I had with Kristine Sinner, who is the owner and founder of Sinnergy Wellness Group. I’ve gotten a chance to work with Kristine over the years, when she started out her private practice she asked for assistance to make sure she was compliant with everything, I was impressed as I don’t usually get those calls on a startup-unfortunately, I usually get those calls after some incident has occurred.
What is especially impressive about this is Kristine’s background as a dietitian, which I have found to pose unique compliance challenges. Since we’ve both worked in eating disorder care, we realize how integral dietitians are to the treatment team and patients’ wellbeing. Unfortunately, that reverence does not seem to be shared across the country, as some states lack licensing requirements for dietitians, which means individuals who do not have formal training or demonstrated competence can claim to be a dietitian. This makes things challenging when it comes to training and understanding of compliance risks-I dare say that dietitians get even less of this training than therapists do.
Despite these barriers, Kristine elected to hold herself to a higher standard of compliance and quality. It was obvious to me she cared about the quality of her program and wanted to make sure everything was done by the book to protect her patients and staff and to be an example of quality behavioral health care.
I hope that more in our industry can follow Kristine’s example to not only provide excellent care but to also be an asset to the generations of care providers that come after us.