Interoperability Matters: The CMS Final Rule and the Path To Compliance
By Dr. Peter S. Tippett, CEO, careMESH.
We are all accustomed to digital tools in our personal and professional lives. Every day, we communicate and receive notifications from others through various methods, such as email, text messaging, online chat sessions and by completing online forms.
We share “structured” documents like spreadsheets, presentations, software source code, or other files by attaching them to email or posting them in shared drives. We also solve misunderstandings, ask questions, drive workflows and coordinate things with “unstructured” content.
In other words, we are living the benefits of full interoperability, allowing different people and organizations to collaborate effectively. Interoperability minimally requires participants to have all three of these capabilities: notification, file sharing and messaging.
To ease communications, reduce provider burden, deliver coordinated patient care, drive down costs and improve outcomes, healthcare needs the same three capabilities. By effortlessly connecting every provider, practice, and hospital, we will deliver an efficient and patient-centric healthcare system.
Earlier this year, before COVID radically changed 2020, the Centers for Medicare & Medicaid Services (CMS) released its Interoperability and Patient Access Final Rule (CMS-9115-F). The rule leverages the might of the agency to “break down barriers in the nation’s health system to enable better patient access to their health information, improve interoperability and unleash innovation, while reducing burden on payers and providers.”
The final rule is far-reaching in its objectives, addressing gaps among payers and healthcare providers, and has seven broad provisions, with three that apply to providers:
1. Admission, Discharge, and Transfer (ADT) Event Notifications (applicable spring 2021) — The most significant impact on hospitals will be due to the (ADT) Event Notifications provision. CMS has modified Conditions of Participation (CoPs) to require most hospitals, including Psychiatric and Critical Access Hospitals, to make a “reasonable effort” to send electronic event notifications to “all” Primary Care Providers (PCPs) or their practice. This will apply for Emergency Department (ED) patients, inpatient admissions and discharges, and transfers to another healthcare facility or community provider. Together with the CMS Promoting Interoperability Programs (formerly Meaningful Use), these initiatives will make pragmatic and substantive progress toward healthcare interoperability. Some states like Florida (FL CS/HB 843) imposed a similar rule that became final in 2019.
This new rule addresses notification; a substantial part of healthcare’s longstanding communications problem. Many Health Information Exchanges (HIEs) have an ADT-oriented notification function, but they and related vendors typically require the PCP to buy the vendor’s service or join the HIE.