EHR Behavioral Health Certification / Adoption Hearing – SMART Vice President Testified

SMART's Vice President of Product and Technology, Paul LeBeau

SMART’s Vice President of Product and Technology, Paul LeBeau

On Tuesday January 28, 2014 SMART’s Vice President of Product and Technology, Paul LeBeau testified at the EHR (Electronic Health Record) Behavioral Health Certification / Adoption Workgroup Virtual Hearing on BH (Behavioral Healthcare) EHR Certification. Providence, RI based SMART Management, Inc. was invited to participate in the Vendor Perspective portion of the work group to offer a professional perspective on how ONC Behavioral Health Certification may impact the field. The following is a summary of his testimony:

“SMART Management started out organically to improve operations of our own substance abuse facilities by automating our information management systems ultimately creating a 100% paperless clinic.  21 years later, SMART Management manages and operates Discovery House, a national system of 18 fully-accredited facilities, and provides a fully-certified EHR solution with more than 120 installations internationally.

Our unique vendor and provider perspective allows SMART to understand both the demands and impact that national certification initiatives place on the end user and the vendor.

We recognized the benefits and value of a widely-adopted EHR Certification standard for healthcare. We chose to certify our EHR for this reason and, from a software provider’s perspective, to ensure business continuity in this changing healthcare environment.

In the substance abuse treatment sector, IT functionality has been fragmented at best. Even today, with many EHR solutions available, there is a wide range of implementations from nothing at all, to several disparate systems that have little or no interoperability.

While our solution is singular, comprehensive and ONC Certified, many of our customers are not pursuing meaningful use incentives, as it would require them to adopt workflows to demonstrate meaningful use that are not meaningful to them in their treatment environments.

While acknowledging the benefits of utilizing a certified EHR, the costs to implement an EHR are substantial. From a consumer’s perspective overall cost of health care provision is increasing while revenue is decreasing. Without some form of incentive, providers who are motivated by improved care, and transitions of care, would have difficulty covering the costs. For this reason, we feel that the potential wide-spread adoption of a voluntary behavioral health certification is low. Without broad adoption, the degree to which information exchange improves care is limited.

For information exchange between primary care and behavioral health to be meaningful and useful, a certification program must be based upon a holistic redefinition of “health care”, treating the whole person, body and mind. Primary care should have more of an interest in substance abuse treatment and substance abuse treatment needs closer involvement with primary care. The Health Homes initiative and State Health Information Exchanges are helping to eventually bring this together.

From the substance abuse treatment perspective, EHR certification would help to improve information exchange, but from a patient perspective, information exchange could be perceived as compromising privacy and confidentiality. This perception is more about the potential re-disclosure of information than it is with the process of sharing the information with a Health Information Exchange.

Confidentiality requirements in substance abuse treatment pose significant challenges to the providers’ ability to participate in data exchange. For example, uploading patient substance abuse data to a Health Information Exchange is problematic, because 42 CFR Part 2 requires signed consents to list all individuals who may access that data. This is difficult at best initially, and impossible to maintain over time as membership in the HIE changes. There are efforts underway (e.g. RI CurrentCare) to establish a process that complies with 42 CFR Part 2, but without revision to those regulations, it seems those efforts will remain hindered.

Beyond the benefits of information interchange, for clinical quality measures to be meaningful, they have to be specific to the healthcare sector. Uniform data assessment and measurement criteria in behavioral health would be needed to benefit the diverse community of providers.

In closing, while SMART is in favor of establishing an ONC Certification Program specifically oriented towards behavioral health, we would encourage that this program:

  • Be incentivized to maximize its potential for success, at the same time broadening the eligible provider pool to include clinicians.
  • Be based upon measures specifically oriented towards behavioral health.
  • Amends 42 CFR Part 2 to support this program, removing a major barrier to its adoption.

Thank you for allowing us the opportunity to offer this testimony and look forward to continued participate in the future.” A part of what makes SMART such a great company to work for is our associates. Each and every member of our team is valued for their individuality and commitment to those we serve.

Get to know our company history…For more than 20 years, SMART’s expertise in managing substance abuse treatment facilities and partnerships with EHR Software customers from around the world has fueled our software innovations.

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