Effective Governance in Behavioral Healthcare Organizations
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By Guest Contributor | October 13, 2026
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As pressures on behavioral healthcare organizations mount, operational complexity compounds with it. With added payer scrutiny, increased regulation, and persistent workforce issues, the need to ensure operational compliance and efficiency has never been greater. As healthcare leaders, we respond to more regulation with more policies, and organizational complexity goes up. This increases the operational risk of something going wrong. One overlooked, misunderstood, misapplied, or ignored policy carries tremendous risk.
Behavioral governance involves designing systems so the right actions happen consistently, even when people are busy, rules are complex, and the organization is growing.
Policy-to-Practice Gap
The late Aubrey Daniels often wrote about “knowing that you know.” As leaders, we develop endless policies. They’re meant to achieve many things, including compliance, financial discipline, and more. But how do we know every person who needs to follow a policy really follows it? All it takes is one manager down the chain who disagrees and chooses not to enforce it. Or an overwhelmed supervisor to look the other way when behavior goes sideways.
Take one example: most organizations have a policy to bill payers for the place of service in which a service is provided. It sounds simple and it should be. Most billing practices are set up to bill the place of service logged in an Electronic Health Record (EHR), making it difficult to bill the wrong location. Here’s what can and has gone wrong:
- If a certain location isn’t pre-authorized, a biller may respond to a denial by rebilling under a different place of service. At least one third party billing company follows this procedure. The organization gets paid, but this violates a policy.
- A well-intended clinician logged into an incorrect place of service. I’m aware of a daycare that has the word “school” in its name. The word “school” doesn’t change the fact it isn’t a school, but a clinician may not know that.
Both the above issues and more create audit risk. Key Performance Indicators (KPIs) may indicate all is well, but people’s behavior is compounding a growing audit risk. How do you know that you know behavior is in line with policy? The need for behavioral governance is clear.
Behavioral Governance Mechanisms
Self-audits are encouraged by payers for good reason. They offer an opportunity to catch issues early and correct them before they escalate. They’re also a way to demonstrate to payers that you’re taking responsibility for your organization’s behavior.