The Centers for Medicare and Medicaid Services’ (CMS) Interoperability and Patient Access E-Notifications Condition of Participation (CoP) deadline is rapidly approaching for hospitals and health systems. From the smallest rural hospitals to the largest health systems, compliance with this CoP brings varying levels of complexity. Large hospitals and health systems face a complex web of challenges – from facilitating workflow consistency to ensuring the quality of patient care and beyond. Variables like these, along with the looming deadline for achieving compliance with the CMS Interoperability and Patient Access Rule E-Notifications Condition of Participation Provision, as well as the pandemic, make for a complex situation, especially for CIOs and administrative professionals who often have more robust IT systems requiring added compliance and technical complexity than smaller hospitals.

Given the significance of the new e-notifications CoP, CIOs and compliance leaders should take time to carefully assess the new requirements to ensure they can meet compliance by May 1st. We’ve compiled a checklist of Q&A’s to help guide you through the process. These questions can be used as a resource to help clarify any misconceptions and provide advice for implementing a CoP solution that addresses the unique pain points that large hospitals and health systems deal with every day.

Does our existing relationship with our EHR vendors ensure 100% compliance with the e-notifications CoP?

EHRs have a critical role to play in enabling interoperability to support policy goals. However, like all software, EHRs are limited by their functional capabilities, adoption within and outside the provider community, and delivery/support model. Unlike the CMS Meaningful Use Program, there are no accompanying set of certification requirements or responsibilities imposed on the EHR (or for that matter, an HIE) in order to meet the e-notifications CoP requirements in the CMS Interoperability and Patient Access Rule. The responsibility is entirely on the shoulders of the health system. As such, it is important that health systems sufficiently evaluate the CoP support being developed by their EHRs to ensure that they successfully comply with this important rule.

Our organization is well-positioned to meet the majority of the compliance requirements. Do we really need to field all external requests for e-notifications from community providers?

For health systems with large provider and post-acute referral networks, hospitals must send e-notifications to community-based providers that have established care relationships with patients, including: primary care practitioners, FQHCs, other entities identified by the patient as primarily responsible for their care, and post-acute providers (skilled nursing facilities, home health agencies, etc.). This information is needed for treatment, care coordination, or quality improvement activities. Therefore, identifying which providers have established care relationships is critical and requires that hospitals, or their intermediary, possess the capabilities to collect patient-identified provider information at the point of care; and obtain care relationship information from providers through a patient roster and notification request process. The roster and notification request process allow providers to identify their care relationships through a roster, such as a patient panel or census list, and receive e-notifications based on hospital care events that match to patients on those rosters. Having these capabilities gives hospitals the ability to determine the required set of providers that need notifications, thereby eliminating e-notification gaps that would lead to non-compliance.

We have a large network of providers and access to a significant amount of electronic data. Is this combined with our HIE network enough to ensure 100% compliance with the e-notification CoP?

HIEs can help with e-notifications compliance, but the hospital is ultimately responsible for ensuring the intermediary it uses is a fully compliant solution. Depending on the HIE’s capabilities, post-acute network coverage, and the hospital’s own geographic reach, there might be gaps that need to be filled. Since most HIEs send notifications only within their state or regional borders, they may not have the required dynamic roster or census capabilities developed to service the full range of providers as required by the CoP. These types of limitations would prevent notifications from being sent in real time on behalf of the hospital to all providers that must receive them. With the ultimate burden of accountability falling on hospitals to meet compliance requirements even if they use an intermediary, it is important for hospitals to proactively assess the capabilities of their HIE in order to avoid non-compliance risk and undue exposure.

We don’t want another layer of technology to log into to send and receive data. Can we handle the requirements internally?

The new CoP promotes the adoption of a more comprehensive information sharing solution, which makes it an important step for improving care coordination efforts nationwide. In order to avoid deficiencies on surveys, hospitals must understand and address all requirements. Any gaps in notification sending and routing will need to be identified and hospital leaders must determine whether to address these gaps by building their own solution or by using an intermediary to supplement existing systems. Large hospitals and health systems setting up their own process for handling the requirements internally should plan for a moderate to significant increase in their operating budgets, as it will require a full assessment of current capabilities compared against the CoP requirements. To meet these requests, hospitals are required to manage patient rosters and match patient care events to those rosters, which then trigger notifications. This means that because care relationships can change daily, patient attribution information from rosters will also need to be updated accordingly, which can increase the technical complexity of managing e-notifications. Beyond this, hospitals will need to establish necessary data share agreements between the hospital and the notification recipient to ensure compliance with all federal and state laws and regulations. For large hospitals and health systems, it is also important to consider any updates to workflows, processes, and human resource requirements for establishing this type of infrastructure in order to determine if they can adequately be met. Many hospitals are finding that alternative solutions are often more cost effective and more easily integrated with existing technology – delivering more insight than a manual approach can provide.

The Centers for Medicare and Medicaid Services’ (CMS) Interoperability and Patient Access E-Notifications Condition of Participation (CoP) deadline is rapidly approaching for hospitals and health systems. From the smallest rural hospitals to the largest health systems, compliance with this CoP brings varying levels of complexity. Apart from the CoP, small-sized hospitals face several unique challenges daily – whether it be limited physicians or more limited access to financing than larger institutions. Variables like these, combined with a global pandemic and looming deadline for achieving compliance with the new CMS CoP, make for a challenging scenario.

For CIOs and IT professionals working in a small-sized hospital, who often lack the compliance and technical support of larger hospital systems, the time to prepare is now. It is critical for small-sized hospitals to understand the intricacies of the new rule and adjust their practices accordingly to ensure 100% compliance with the e-notifications CoP. Below is a list of common Q&A’s to consider when assessing what, if any, changes your hospital needs to make. These questions can be used as a resource to help clarify any misconceptions and provide advice for implementing a CoP solution that addresses the unique pain points that small hospitals deal with every day.

Does my hospital’s existing relationship with our EHR vendor ensure 100% compliance with the e-notifications CoP?

While most EHR vendors typically provide solutions to enable Direct Messages upon inpatient events, in particular discharge events, as was specified under Meaningful Use, the new CoP notification requirements are expanded where hospitals must send notifications upon all inpatient and emergency department events. Furthermore, those notifications must not only be sent to providers identified in the EHR but also to those providers with attributed patients that request notifications to support treatment and care coordination activities. To do so, solutions need three key components: 1) manage notification requests from patients’ attributed providers across the care continuum, 2) accurately match patients’ care events, and 3) send notifications based on the matches in real-time to the appropriate practitioner or entity. Any hospital that aims to rely on its EHR vendor to meet compliance requirements should assess whether the vendor can indeed offer a complete solution and how it might guarantee compliance.

Most of our patients are local. Is our HIE able to ensure 100% compliance with the e-notification CoP?

The CoP requires e-notifications be sent at the time a patient event occurs to any established practitioner, practice group/entity, or post-acute regardless of their geographic location. While most care events in your smaller system may be local, the CoP requires that your hospital account for all scenarios to ensure care coordination both within your system and beyond so you must account for scenarios such as a patient traveling across state lines. Since most HIEs send notifications only within their state or regional borders, they may not have the required dynamic roster or census capabilities developed to service in the full range of providers as required by the CoP. Such limitations would prevent notifications to be sent in real time on behalf of the hospital to all providers that must receive them. Since hospitals will be ultimately held accountable for meeting compliance requirements even if they use an intermediary, hospital leaders should evaluate their HIE’s capabilities and assess if they might face non-compliance risk and undue exposure. As a small hospital system, we’re looking to save costs as much as possible.

What kind of increase can our hospital expect to see in our operating budgets by setting up this process?

Can we handle the requirements internally? The CoP intends for hospitals to adopt a more comprehensive information sharing solution, so hospitals must understand and address all requirements to avoid deficiencies on surveys. Hospitals planning to set up a process to handle the requirements internally will need to plan for a moderate to a significant increase in their operating budgets, as it will require a full assessment of their current capabilities compared against the CoP requirements. Meeting these requests will require hospitals to manage patient rosters and match patient care events to those rosters, which then trigger notifications. Because care relationships can change daily, especially in the post-acute setting, patient attribution information from rosters will also need to be updated accordingly, which can increase the technical complexity of managing e-notifications. In addition, any necessary data share agreements need to be in place between the hospital and the notification recipient to ensure compliance with all federal and state laws and regulations. Hospitals should consider the workflows, processes and human resource requirements for establishing this type of infrastructure to determine if they can adequately address them. In most cases, an alternative solution can be more cost-effective and provide more insight than implementing a manual approach.

We can afford to take on more risk than a larger hospital system, so why do we need to prioritize this requirement now?

Every hospital from small to large is governed by this rule, so the necessary data share agreements need to be in place between the hospital and the notification recipient to ensure compliance with all federal and state laws and regulations. Given the significant consequences of non-compliance, hospitals of all sizes need to assess their existing notification capabilities and identify any gaps as quickly as possible as building a solution or vetting a third-party intermediary will require time. As the May 1, 2021 compliance deadline approaches, hospitals need to consider the workflows and processes they have in place to meet these requirements and whether they can adequately address them.

The Centers for Medicare and Medicaid Services’ (CMS) Interoperability and Patient Access E-Notifications Condition of Participation (CoP) deadline is rapidly approaching for hospitals and health systems. From the smallest rural hospitals to the largest health systems, compliance with this CoP brings varying levels of complexity.

Today’s mid-sized hospitals can face their own set of challenges ranging from the increased demand for service lines, growing patient populations, and the need to share data with regional health exchanges while complying with expanding regulatory requirements. Considerations like these, combined with the COVID-19 pandemic and impending deadline for achieving compliance with the CMS Interoperability and Patient Access Rule E-Notifications Condition of Participation Provision, make for an overwhelming task, especially for CIOs and administrative professionals who typically have more complicated systems than small hospitals, with fewer compliance and technical support staff than larger hospital systems.

With the May 1st deadline rapidly approaching, we’ve compiled a list of Q&As to help guide you through the process. These questions can be used as a resource to help clarify any misconceptions, avoid deficiencies that could jeopardize your CMS certification status, and provide advice for implementing a CoP solution that addresses the unique pain points that mid-sized hospitals face on a daily basis.

As a mid-sized hospital, we have a large local network of providers. Is our HIE able to ensure 100% compliance with the e-notification CoP?

Even though most care events in your mid-sized hospital network may be local, the new CoP requires e-notifications be sent at the time a patient event occurs to any established practitioner, practice group/ entity, or post-acute regardless of their geographic location. This means that your mid-sized hospital must ensure care coordination both within your system and beyond, which requires the consideration of scenarios such as a patient traveling across state lines. Because most HIEs send notifications only within their state or regional borders, they may not have the required dynamic roster or census capabilities developed to service in the full range of providers as required. Limitations such as these would prevent real-time notifications from being sent on behalf of the hospital to all necessary providers. As a result, it is critical for hospitals to evaluate your HIE’s capabilities in order to avoid non-compliance risk and undue exposure, as even if you use an intermediary, hospital leaders are ultimately held accountable for meeting compliance requirements.

Our mid-sized hospital already has an existing relationship with EHR vendor(s). Do we already have the capabilities to field all external requests for e-notifications from community providers?

Most EHR vendors typically provide solutions to enable Direct Messages upon inpatient events, in particular discharge events, as was specified under Meaningful Use. However, the new CoP notification requirements are expanded where hospitals are required to send notifications upon all inpatient and emergency department events. To support treatment and care coordination activities, this rule expansion also makes it so those notifications must be sent to providers identified in the EHR as well as to those providers with attributed patients that request notifications. As a result, your hospital’s solution must: 1) manage notification requests from patients’ attributed providers across the care continuum, 2) accurately match patients’ care events, and 3) send notifications based on the matches in real-time to the appropriate practitioner or entity. This means that it is most likely not enough to rely on your EHR vendor to meet compliance requirements. You can assess this by approaching your EHR vendor directly. Ask them if your existing EHR solution has the ability to guarantee compliance with the new rule.

We don’t want another layer of technology to log into to send and receive data. Can we handle the requirements internally?

The ultimate goal of the new CoP is for hospitals to adopt a more comprehensive information sharing solution. As a result, it is critical for mid-sized hospitals to fully understand and address all requirements in order to avoid deficiencies on surveys. Hospitals should plan for a moderate to significant increase in their operating budgets if they wish to establish a process to handle the requirements internally because it will require a full assessment of current capabilities compared against the requirements of the CoP. To meet CoP requests, your hospital will need to have the capability to manage patient rosters and match patient care events to those rosters, which then trigger notifications. Also, since care relationships can change daily, your mid-sized hospital will need to plan for an increase in the technical complexity of managing e-notifications as your patient attribution information must be updated from rosters accordingly. To determine if your hospital can adequately address the requirements, you will need to consider the added workflows, processes and staffing requirements for establishing this type of infrastructure, as well as account for any necessary data share agreements between the hospital and the notification recipient to ensure compliance with all federal and state laws and regulations. Due to this level of complexity, many mid-sized hospitals are finding that an alternative solution can be more easily integrated with existing technology and is often more cost effective to implement a manual approach.

Amidst COVID-19 and other initiatives, our hospital has a lot going on. Do we need to prioritize this requirement right now?

Necessary data share agreements need to be in place between the hospital and the notification recipient to ensure compliance with all federal and state laws and regulations. As a result, hospitals of all sizes need to assess their existing notification capabilities and identify any gaps as quickly as possible, as building a solution or vetting a third-party intermediary will require time, and there will be significant consequences of non-compliance. Mid-sized hospitals assessing their priorities should consider the workflows and processes they have in place to meet these requirements and whether they can adequately address them in time for the May 1st compliance deadline.