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...support from diverse groups to keep hospital doors open, psychiatric hospital administrators have a long history of being advocates for what it takes to make a difference in the lives of people with some of the most serious mental illnesses.
But in recent years the pace of change in the psychiatric hospital field has accelerated dramatically. From my vantage point as the chief operating officer of Sheppard Pratt, one of the country's most venerable private psychiatric health systems, and as the recent president of the National Association of Psychiatric Health Systems (NAPHS), I see a number of specific changes on the administrative front. Comparing these changes to the past can help us better understand where we are today and what actions administrators can take to prepare for ever-accelerating change.
What Has Changed
More regulation. Today a wide array of regulations (such as EMTALA and HIPAA) affects hospitals. Hospitals are subject to the rules and, in many cases, inspections of scores of agencies, including:
* federal agencies (such as HHS, CMS, OSHA, DOE, FDA, DOD, and FBI);
* accrediting bodies (such as The Joint Commission, CARF, and COA); and
* state agencies (such as departments of health, mental health, substance abuse, family services, child welfare, justice, and education).
Subsequently, a large portion of each day, not just for administrators but also for clinicians, is devoted to paperwork. Yet the most complex and detailed regulatory requirements--those associated with Medicare and Medicaid--did not exist until 1965. In fact, between 1991 and 2001 Medicaid grew to become the largest payer of mental healthcare with prescription drugs the fastest-growing spending component. (1) Before federal reimbursement programs, regulation was primarily at the state level and was more idiosyncratic to state sensibilities.
Conflicting regulations can leave hospitals caught in the middle. For example, EMTALA requires all hospitals to treat emergency patients, but federal institutions for mental disease (IMD) restrictions actually prohibit Medicaid funding for these patients in freestanding psychiatric hospitals. The growing burden of duplicative and conflicting...
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