HIPAA’s not just for hospitals
Most counties and behavioral health organizations aren’t compliant with the HIPAA Security rule, but don’t take my word for it. Download the HIPAA Security Rule directly from HHS and read it over the weekend. If you want to talk about it, grab a 30-minute slot in my calendar and we’ll discuss your security policies and procedures at no charge.
Read more about our HIPAA services for counties and behavioral health organizations.
For more background, read Jeff’s articles on HIPAA
- Risk assessments for local governments and SMBs. CIO.com, May 2017.
- HIPAA as an umbrella for county/municipal cybersecurity. CIO.com, April 2017.
- County and municipal cybersecurity – Part 2. CIO.com, April 2017.
- County and municipal cybersecurity – Part 1. CIO.com, March 2017.
- May I see your comprehensive security policy please? CIO.com, October 2016.
- The ACA and the death of medical privacy. CIO.com, August 2016.
- Why should county commissioners and executives care about HIPAA? Careers in Government, February 2018.
© Copyright Jeffrey Morgan, 2018
© Copyright Jeffrey Morgan, 2018
As a Mental Health Commissioner or Director of Community Services, purchasing the right EHR & Practice Management System will be one of the most important business decisions of your career. Even for a relatively small practice, you will spend at least several hundred thousand dollars once all the relevant modules, training, data migration, and implementation are accounted for. It’s an overwhelming decision on top of DSRIP, ACA and all the other changes in the industry.
One of the big problems with purchasing such a system is the learning curve. If you are new to the procurement of major systems, you probably don’t have all the tools you need to get through the process. The second problem is all about assumptions. Managers who are new to software procurement often make the assumption that the software company is providing a turnkey solution. Here is the ugly truth: the software company will only do exactly what you asked for in the RFP. Anything you forgot will cost extra. Even if you are purchasing a turnkey solution, there is still a great deal of work for you and your staff to do. Here is a link to my article about software implementation models.
First, let’s talk about some of the tools you will need as well as the general approach to the procurement process you should be taking. Then, we’ll discuss some of the specifics for EHR/Practice Management systems.
The 12 Step Program for Software Procurement
I have written about this before in other contexts, but the basic process is the same whether you are purchasing an ERP, EHR, CRM, or any other type of system. Following is a summary of the basic steps with links to more detailed discussions of the specific steps.
- Draft a Project Charter
- Establish a Procurement Committee & Appoint a Project Manager
- Conduct a Business Process Review
- Identify and Document Goals, Objectives and a Preliminary Budget
- Conduct a Needs Assessment
- Analyze and document your Information Technology Infrastructure
- Document Environmental Factors and Organizational Culture
- Draft and release an RFP (Request for Proposal) or IFB (Invitation for Bid)
- Review Proposals and Prepare a Short List for Demonstrations
- Hold Software Demonstrations & Select a Solution
- Customer and Vendor Site Visits
- Negotiate and execute the Contract
You may have noticed that drafting and issuing an RFP comes late in the project. In many of the failed projects I have studied and reviewed, the buyer treated the RFP as the first step rather than one of the final steps. Moreover, I have presented the steps sequentially, but they don’t need to be so. For instance, steps 3-7 can be conducted concurrently if you have a staff member or consultant with the skills to do so.
It sounds like a simple process, and it is. It’s going to take more than 15 minutes to put it together, however. If you are truly using due diligence, it may take several weeks to gather all the information required to assemble your RFP.
Behavioral Health Specific Questions – Some Considerations
In addition the procedures described above, there many industry specific factors to consider. I provide a summary of some of these issues below in the form of questions. However, this is not intended to be an exhaustive discussion. Please e-mail me if you wish to discuss your project in more detail and we can setup an appointment to talk. The first hour is free!
Are the systems you are reviewing certified for all 3 stages of Meaningful Use?
Forms & Regulatory Compliance
What forms do you currently use? Are your forms fully compliant with both Medicaid and NYSCRI or other state specific forms? Does the vendor have a major presence in your state and are they committed to the immediate implementation of regulatory changes for your state? Will there be an extra charge for unexpected regulatory changes? Will you require custom forms with custom mandatory fields?
HL7 and Interoperability
Do you need RHIO connectivity? Right now or down the road? What sort of impact will DSRIP have on your project?
Third Party Hardware and Software
What third party hardware and software is required for the system? How much does it cost and what will be the 5 year TCO?
Will the system allow you to go paperless? What about the cost of scanners? Will you use a centralized or distributed model for document imaging? What are your state’s regulatory requirements for scanning? Most states have specific legal and procedural requirements for document imaging. For New York, the requirements can be found here. Is your software in compliance with state imaging guidelines?
What is your workflow from initial client contact forward? Every agency has a different workflow and quality EHR systems have flexible workflows that can be adapted for your specific requirements. Do you have flowcharts? Do you want to change your workflow to a more efficient model during implementation? What will your new workflow look like? Who is going to configure rules and alerts for Treatment Plans, etc? What is the workflow between clinician and billing?
Total Cost of Ownership (TCO)
What is the real 5 year TCO of your system including maintenance, support, consulting services, implementation and third part products?
Return on Investment (ROI)
What will the ROI of your system be? Will productivity improvements allow you to reduce staff or will you have to add staff?
SaaS Vs. Customer Hosted
Do you have the infrastructure to host the system internally? Or does a SaaS (aka “Cloud”) system make more sense? Which makes more sense from a business perspective and what are the long term costs and consequences of each type of system? What are the pros and cons of each system?
Do you have a Comprehensive Information Security Policy? Is the software you are purchasing flexible enough to implement your security policy in the system? Do you have an information security officer? Who will monitor and document system security?
What are your reporting requirements? Will you staff need special training to build reports? Have you included required reports in the RFP? Does the software allow you to easily build required CFR’s?
Who is going to handle the data migration? Most vendors insist that you supply the data to them in a specific format. Do you have staff members who can extract the data from your old system and provide it to the vendor in the requested format? Who is going to validate the migrated data and how long will it take?
Do you have a comprehensive list of Payors and Clearing Houses? Each of these will have to be configured individually. How will your system handle write downs? Cash Payments? Credit Cards? Invoicing? Are you still doing any paper billing or is it all electronic? What billing forms do you use and are all these supported by the system?
Installation, Implementation, Configuration
Have you budgeted for sufficient professional services to get the project completed without excessive cost overruns? Are you going to implement EHR and Billing simultaneously? Or in stages? What is your timeline?
Have you budgeted for sufficient training and Go Live support? No matter how much training you have built into the project, I assure you that you will need more than you think.
I get it. You are Mental Health Professionals, but transition to a new EHR/Practice Management System is a painful process and Change Management is something that must be considered.
You may wish to read my article on writing RFP’s before you get too far down that road.
EHR/Practice Management projects are only successful when the executives provide unwavering support and dedication. These sorts of projects don’t succeed or fail by accident. You will have to roll up your sleeves and get your hands dirty to succeed with the minimum amount of pain.
As I have already indicated, this is a partial list of questions you should be considering before you write an RFP. Please e-mail me at firstname.lastname@example.org if you would like to discuss your EHR or Practice Management System Requirements.by