How the CMS Interoperability and Patient Access Rule Creates a Vision for Interoperability and the Delivery of Whole Person Care

How the CMS Interoperability and Patient Access Rule Creates a Vision for Interoperability and the Delivery of Whole Person Care

As of May 1, 2021, U.S. hospitals must comply with the Centers for Medicare and Medicaid Services (CMS) Interoperability and Patient Access Rule electronic event notifications (e-notifications) Condition of Participation (CoP) requiring hospitals to send Admission, Discharge, and Transfer (ADT) e-notifications to all requesting post-acute providers, primary care providers, and primary care entities.

The CMS e-notifications CoP is designed to help hospitals better serve their patients through improved care coordination and enhanced interoperability among providers. This is done by requiring hospitals, psychiatric hospitals, and critical access hospitals to share electronic ADT-based care e-notifications with other community-based providers and care team members, including post-acutes. This means that all hospitals utilizing an electronic health record (EHR) service provider or other electronic administrative system that is conformant with the content exchange standard HL7 v2.5.1, must make a reasonable effort to send real-time electronic notifications.

For reference, CMS states that the reasonable effort means sending the ADT e-notifications:

  • At: the point of inpatient and observation admission, discharge, and transfer, and at emergency department (ED) presentation and discharge;
  • To: the patient’s established primary care provider (PCP), established primary care practice group or entity, other practitioners, practice groups or entities identified by the patient as primarily responsible for his or her care, and applicable post-acute providers who need to receive notification for treatment, care coordination, or quality improvement purposes;
  • Containing: at minimum the patient’s name, treating practitioner’s name, and sending institution’s name.

While the deadline for hospitals to comply with the CMS E-Notifications CoP has passed, it does not mean a hospital’s job and mission to improve care coordination is done. Despite the rule now being in effect, many hospitals have begun to think about the road ahead and how it’s beneficial for new care approaches like whole person care. These approaches can allow healthcare providers that have integrated a CMS-compliant solution to introduce new levels of visibility into a patient’s care journey with e-notifications.

Reaching Beyond the E-Notifications CoP Toward Interoperable Whole Person Care Coordination

Over the past few years, there have been numerous changes to the interoperability and value-based care landscape. With new rules proposed and finalized, innovation models created and phased out, directional changes in the industry are favoring a focus on care coordination. With rules from ONC and CMS, and updates from CMS and the Center for Medicare and Medicaid Innovation (CMMI), the industry continues to rapidly evolve and look to support future care coordination needs.

By requiring hospitals to send real-time e-notifications at the point of inpatient admission, discharge, and transfer, and at ED presentations or discharges, CMS took a step forward to ensure that all providers will ultimately have access to timely information to further care coordination. The result is an advancement toward the growth of value-based care delivery models and increased interoperability across the care continuum, with each of the two further driving the other.

While much may change in the coming years, care coordination remains at the heart of both sides of this equation. Sharing real-time information via ADT events about patients’ care encounters across providers introduces new levels of visibility for respective care teams, driving whole person care initiatives which can reduce ED utilization, prevent hospital readmissions, avoid unnecessary procedures and tests, eliminate medication errors, treat behavioral health problems holistically, and identify and manage social determinants of health.

New technology solutions are now supporting whole person care and can ensure that hospitals achieve compliance with the CMS e-notifications CoP and deliver enhanced value-based care coordination initiatives. By enabling healthcare providers with insight into the patient care journey, they gain a new understanding of all the issues that an individual is dealing with so they can prioritize and coordinate care plans to improve health outcomes.

At Bamboo Health, our healthcare solutions are facilitating exactly that. No matter who the provider is, no matter what the care setting is, they can look at the individual as a whole person and uniquely coordinate how they are going to care for that patient. This technology, paired with our expansive national footprint, arms healthcare providers across the country with a greater view into all of the conditions that an individual is managing, creating a whole person view that powers whole person care.

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