Healthcare regulation is usually judged by its destination: better quality, broader access, lower cost. Far less attention goes to the transition, when provider organizations must redesign workflows, update reporting systems, and retrain staff while continuing to see patients.
Regulatory change here is broad. It includes new reporting and documentation rules, changes to payment and reimbursement models, and the compliance obligations that govern who may treat patients and bill for care. Obligations arrive uniform and fixed, while the infrastructure and funding to meet them arrive fragmented and uneven, and that gap is where regulatory change gets expensive.
Regulatory Change Is Never a Single Change
New requirements rarely alter one thing. They typically ask providers to modify documentation, reporting, billing, and quality measurement at once, without retiring anything that came before.
Evidence of that adjustment period shows up in Medicare cost reporting. Examining short-term acute care hospitals before and after implementation of the Affordable Care Act (ACA), researchers found a sustained increase in amended Medicare cost reports, consistent with greater reporting complexity during the transition rather than immediate adaptation (Di Paolo Harrison, Braymen, and Hoag, 2022).
The same study offers a corrective. Hospitals also corrected fewer entries per amended report and reopened settled reports less often over time, which the authors read as diligence rather than deteriorating accuracy. The signal is not carelessness; it is the cost of learning a new process while the old one still runs.
The Cost Lands Where Requirements Diverge
Providers do not implement a regulatory change once. They implement it separately for every payer they bill, every state they practice in, and every facility where they treat patients.
Credentialing is the clearest everyday example. Each payer maintains its own enrollment requirements and revalidation cycles, each state its own licensing board and renewal schedule, each facility its own privileging and reappointment process.
Research on payment reform documents the same structure. The National Academy of Medicine has described how individual payers use differing and sometimes multiple payment approaches, and how that variation, combined with divergent transition strategies, drives marketplace complexity. The same analysis identifies broad payer alignment as a precondition for providers committing to value-based care (National Academy of Medicine, Vital Directions).
The consequence is documented at the state level. An examination of Tennessee's episodes-of-care and medical home strategies found that differing design features across payers, including practice qualification standards and reporting measures, produced significant variation that discouraged low-volume providers from participating (Princeton School of Public and International Affairs, 2016).
Multi-stakeholder research reaches the same conclusion from the opposite direction. Across projects in six states, recurring obstacles included incompatible information systems, the transaction costs of altering existing billing systems, and competing stakeholder priorities (Conrad et al., 2014). In several projects the binding constraint sat with the health plans rather than the practices, which is the point: when requirements fail to align, providers carry the reconciliation.
Obligations Are Uniform, Support Is Not
The clearest illustration of the asymmetry is not a payment model. It is a funding decision.
The 2009 Health Information Technology for Economic and Clinical Health (HITECH) Act created incentive payments for hospitals and eligible professionals to adopt certified electronic health records (EHRs). Substance use and mental health treatment facilities were excluded, and adoption and interoperability gaps persisted as a result (Office of the National Coordinator for Health Information Technology, 2024).
Those facilities still face every expectation that follows from digitization, from quality reporting to record exchange, having been left out of the program that funded everyone else's capacity to meet them.
Behavioral Health Shows the Pattern Most Clearly
Current federal data complicates the familiar story. More than two-thirds of substance use and mental health treatment facilities now use an EHR exclusively, with another quarter using electronic records alongside paper. Adoption is not the binding constraint.
Exchange is. Only about one in five reported participating in a health information exchange (HIE), the infrastructure that makes records usable across settings. A facility can be fully digital and still unable to send anything anywhere.
That matters because coordinated and value-based arrangements depend on data moving between organizations, not merely existing inside one.
Reimbursement Compounds the Load
Behavioral health providers also operate against a payment gap. Analysis of commercial claims covering more than 22 million people annually from 2019 through 2021 found in-network office visit reimbursement averaged 22 percent higher for medical and surgical clinicians than for behavioral clinicians (Mark, Fujita, and Parish, Psychiatric Services).
The same research found patients went out of network 3.5 times more often to see a behavioral health professional than a medical or surgical one. Reimbursement rates, the administrative inconvenience of joining a plan, and the burden of getting paid once enrolled all shape whether clinicians participate in networks at all (Hobbs Knutson, Wennberg, and Rajkumar, 2021).
Administrative friction is therefore not only an operational cost. It is one input into whether a patient can find in-network care.
Accountability Design, Not Measurement Difficulty
Behavioral health quality measurement is often framed as inherently harder to pin down. The more precise problem is accountability design and reporting capacity.
Across the payment reform literature, provider opposition to being held accountable for outcomes they cannot fully control is among the most frequently reported barriers (Ndayishimiye, Tambor, and Dubas-Jakobczyk, 2023). A 2026 review found that consensus on behavioral health quality metrics remains poor across several hundred candidate measures, most of them process measures drawn from claims data, and that the push for aggregate outcome reporting has outpaced the field's capacity to collect and report it (npj Mental Health Research, 2026). Measure development for behavioral health also lags general medical care (Quality Measures at the Interface of Behavioral Health and Primary Care).
Validated patient-reported measures exist and are clinically meaningful. What is missing is the infrastructure to collect, standardize, and transmit them at scale, which returns the problem to capacity rather than clinical ambiguity.
What Actually Reduces the Friction
The literature is reasonably consistent about what helps: alignment across requirements, standardized measures, interoperable information systems, and adequate implementation resources.
Three of those four are coordination problems rather than policy problems, describing the work of reconciling payers', states', and facilities' requirements, formats, and timelines into something a practice can execute.
This is where credentialing and compliance technology has a defined role. CareLumi's technology-enabled credentialing workflow platform can organize requirements by payer and jurisdiction, track expirations and revalidation cycles, and standardize documentation, reducing compliance friction without altering the underlying rules. Third-party review timelines and approval decisions remain outside any platform's control, which is why the addressable problem is preparation and coordination rather than outcomes.
Looking Past Regulatory Design
Regulatory change is evaluated on whether it improves quality, lowers cost, or expands access. Those remain the right measures. But requirements are executed by provider organizations, and execution capacity is distributed unevenly.
When obligations arrive uniform and support arrives fragmented, the cost concentrates in the organizations least equipped to absorb it. In behavioral health, where administrative capacity and exchange infrastructure are thinnest, that concentration shows up in network participation and therefore in what patients pay. Reducing that friction will not make regulatory design easier, but it will determine how much of any given change survives contact with the clinic.
Sources
- Di Paolo Harrison, Braymen, and Hoag (2022): The Influence of Regulatory Change on Hospital Cost Reporting
- National Academy of Medicine: Vital Directions for Health and Health Care
- Princeton School of Public and International Affairs (2016): TennCare Payment Reform Report
- Conrad et al. (2014): Multi-Stakeholder Payment Reform Across Six States
- Office of the National Coordinator for Health IT (2024): EHR Adoption and Exchange Among Substance Use and Mental Health Treatment Facilities
- Mark, Fujita, and Parish: Behavioral Health Reimbursement Analysis, Psychiatric Services
- Hobbs Knutson, Wennberg, and Rajkumar (2021): Network Participation and Administrative Burden
- Ndayishimiye, Tambor, and Dubas-Jakobczyk (2023): Barriers to Payment Reform Implementation
- npj Mental Health Research (2026): Behavioral Health Quality Measure Consensus Review
- Quality Measures at the Interface of Behavioral Health and Primary Care
Erick Lopez is a Regulatory Research Intern at CareLumi.