The Centers for Medicare and Medicaid Services (CMS) created a new electronic event notification (e-notification) Condition of Participation (CoP) as part of the Interoperability and Patient Access Rule. This rule aims to significantly accelerate information sharing between hospitals and other providers across the care continuum.
CMS used its most consequential regulatory lever, Conditions of Participation, to create the new e-notification requirement, showing the importance the agency places on increasing provider access to necessary patient information and breaking down silos across providers. Facilitating information sharing amongst providers can help address an estimated nearly $80 billion in waste due to inadequate care coordination. Most importantly, patients receive better outcomes through effective and comprehensive coordinated care.
The new requirement goes into effect May 1, 2021 and is not expected to be delayed. As the deadline rapidly approaches, hospital CIOs, IT teams, and compliance officers should begin understanding the rule’s components and vetting solutions to help ensure they meet all of the e-notification requirements.
Sending E-Notifications: Who, When & Where?
The new electronic event notification CoP requires hospitals, psychiatric hospitals, and Critical Access Hospitals to make a reasonable effort to send e-notifications either directly or through an intermediary at the point of emergency department presentation/registration and discharge as well as at the point of inpatient admission, discharge, and transfer.
Notifications may be requested from any specified practitioners, practice groups, or entities, and applicable post-acute care providers and suppliers with established care relationships that need the patient information for treatment, care coordination, or quality-improvement activities.
Key Considerations for Hospitals
To evidence reasonable effort, and thereby meet the minimum compliance requirements, hospitals must implement policies, processes, and systems that determine established care relationships across the required recipient types and send e-notifications accordingly. To determine these care relationships, hospitals need the ability to not only obtain patient-identified provider information at the point of care, but to also obtain care relationship information from applicable recipients through a patient roster and notification request process.
Hospitals or their select intermediaries will also need to be able to:
1. Match patient events accurately to ensure appropriate data disclosure
2. Assure security protocols and required data sharing agreements are in place
3. Send e-notifications in real-time for the required care events, consistent with patients’ privacy preferences and applicable law, to the specified recipient(s).
Demonstrating these capabilities supports CoP compliance efforts and helps support hospitals in their efforts to reduce information blocking practices in accordance with the provisions outlined in the ONC’s Cures Act Final Rule.
The Rapid Path to Compliance
By the May 1, 2021 deadline, hospitals must meet the minimum compliance requirements to send electronic Admission, Discharge, Transfer (ADT) based e-notifications to both patient-identified providers and applicable post-acute care providers with established care relationships that need the patient information for treatment, care coordination, or quality improvement activities. Rhapsody and PatientPing partnered to ease this compliance burden.
Rhapsody health solutions customers already have all the necessary ADT messages flowing through their Corepoint or Rhapsody interface engines, and PatientPing is an expert managing patient roster functionality and delivering real-time e-notifications to its national network of over 5,000 post-acute providers.
With this as our driving force, we co-created a connector that seamlessly interoperates between Corepoint and Rhapsody engines and PatientPing’s Route solution. Route alleviates hospitals’ compliance IT and data-sharing burdens by delivering e-notifications to providers as identified by patients, as well as to requesting community provider groups.
Additionally, the solution manages all of the complexities involved with sending required e-notifications, from executing data-share agreements with all e-notification recipients to managing and executing the frequent, real-time changes to a diverse array of patient roster types to track patient/provider attribution.
Ready to learn more about how Rhapsody health solutions can help you meet compliance deadlines? Let’s talk.