Hospitals Have Six Months to Meet CMS Requirements on Patient Event Notifications

March 9, 2020
The admission, discharge and transfer (ADT) notification requirement also applies to patients registered in an emergency department, whether they are admitted to the hospital or not

Among its other provisions, the Centers for Medicare & Medicaid Services’ interoperability final rule starts the clock for hospitals to make sure they are electronically sharing patient event notifications with patients’ primary providers within six months.

Patient event notifications refer to admission, discharge and transfer (ADT) information about patients, often sent through health information exchanges, to improve care coordination. Usually CMS requirements for Conditions of Participation (CoP) in Medicare and Medicaid go into effect 60 days after a final rule is published, but after receiving many responses to the proposed rule for more time, CMS chose to put this requirement into effect in six months.

In its final rule document, CMS noted that it received more than 600 public comments on the section specific to patient event notification requirements. Many were positive. One commenter noted that the statewide requirement for hospitals in Maryland to transmit notifications has been an important policy supporting care coordination in the state. Others noted it is especially important for the success of value-based payment models such as accountable care organizations (ACOs), where participants may be financially at risk for costs associated with poor care transitions.

 However, many responses to the proposed rule raised concerns about making event notifications mandatory conditions of participation, stating that it would increase regulatory burden at a time when HHS is working in other areas to decrease regulatory burden on provider organizations.  

But CMS disagreed, noting that if small, rural hospitals don’t have an EHR that can share event notification data, they are exempt from the new rule. CMS also claimed there are many ways for hospitals to minimize the burden through use of HIEs.

 Among the clarifications in the final rule is that the patient notification requirement also applies to patients registered in an emergency department (ED), whether they are admitted to the hospital or not. The rule requires one notification when a patient is registered in a ED and another when admitted to hospital, but not when a patient is transferred between different areas of a hospital.

 Commenters were also concerned about how hospitals would know all the providers that have an “established care relationship” with a patient. CMS agreed that could be challenging and sought to narrow the definition to their primary care providers or other providers identified by the patient as primarily responsible for his or her care. If hospitals cannot identify a primary care or post-acute care provider, then they don’t have to send event information.

 Other commenters raised concerns about patient matching, but CMS responded by saying this use case actually presents an opportunity to lead the way on developing innovative solutions to patient matching.

Stakeholders involved in HIEs and ACOs applauded the final rule. On Twitter, Claudia Williams, CEO of Manifest MedEx, a California nonprofit health data network, called it “an aggressive and appropriate deadline. Alerts work to improve quality and reduce readmissions.”

Travis Broome, vice president for policy and ACO administration for Aledade, noted on Twitter that this move is necessary because it is directly related to patient safety. “Transitions are dangerous and there is no excuse for them to happen in the dark,” he said. He added that ADT is the easiest data exchange out there by a mile — it has high impact and low barriers.

 Broome explained that previously ADT was getting caught up in more complicated exchanges. “Some hospitals were either making it unnecessarily difficult by wrapping it up with lab data and other data or they were blocking access to the data altogether for business reasons,” he wrote. To break through, CMS required only the most straightforward of data be shared, Broome noted. “CMS made real concessions on feasibility while ensuring that the most important patient safety element of awareness of the transition is supported. A good balance.”

Hospital associations might have different opinions. We will update our coverage as more reaction comes in. 

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