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Complying with CMS’s patient event notification CoP: common pitfalls to avoid

Hospitals must comply with CMS’s patient event notification Condition of Participation (CoP) by April 30, 2021. The CoP requires all hospitals with an EHR – including critical access and psychiatric hospitals – to send electronic patient notifications for patient admissions, discharges and transfers to primary care providers, physicians and post-acute providers and suppliers. With less than three months remaining until the deadline, it is essential that hospitals and health systems identify and implement a solution to ensure compliance as soon as possible.

Below, we clear up some common misconceptions regarding the new CoP, and what’s required in order to comply – to ensure that your organization is in compliance with the new requirements, fulfills the CoP and avoids putting Medicare funding at risk.

My hospital’s HIE will provide compliance

Hospitals seeking to comply with CMS’s new CoP may assume their participation in an HIE fulfills this CoP requirement.

Contributing an ADT feed to an HIE does not guarantee compliance. Hospitals must make a reasonable effort to ensure the notifications are actually sent to the wide swath of recipients required by the rule. HIEs are often unable to identify and notify out-of-state providers, and may not be able to send notifications in real time – critical to achieving compliance. HIEs may also not always have the means to capture and identify the physician primarily responsible for a patient’s care, or have visibility into a patient’s care prior to or after a hospital admission, discharge or transfer from only a hospital ADT. Further, any physician, post-acute provider or supplier that is not an HIE subscriber will not receive HIE alerts unless they pay to subscribe.

Though HIEs can retrieve some information from a hospital’s ADT feed, such as a physician’s NPI, not all physicians have NPIs included in the ADT, and any additional physicians identified by the patient – such as a specialist like an endocrinologist or oncologist – may not be captured. To comply with the CoP, a hospital would need to make a reasonable effort to notify all of these providers, which is unlikely by just sending an ADT to the HIE.

My hospital’s EHR can guarantee compliance

Many EHRs offer a solution that addresses physician notifications, but do not offer a comprehensive interoperability solution for post-acute providers. EHRs have not implemented a solution that can identify and notify the appropriate post-acute provider – whether SNF, home health, LTACH, IRF, hospice or DME suppliers – when a patient is admitted, discharged or transferred from the hospital. Transfers present the biggest obstacle for hospital EHRs; though a hospital may be able to manually identify admitted patients, transfers are more complex and likely require a dedicated third-party solution.

If I comply with Promoting Interoperability or 21st Century Cures, I also comply with the CoP

As hospitals work to comply with CMS’s patient event notification CoP requirements, it is critical to understand the broader regulatory framework – including CMS’s Promoting Interoperability and the ONC’s 21st Century Cures Act – and how the new patient event notification CoP fits within this existing framework.

Though program requirements may seem similar, CMS’s new patient event notification CoP is not part of the Promoting Interoperability Program, nor can hospitals demonstrate compliance with the CoP simply by participating in Promoting Interoperability. These programs are measured differently; whereas the CoP focuses on patient event notifications, Promoting Interoperability instead prioritizes making meaningful use of a certified EHR.

To make the regulatory landscape that much more confusing, CMS’s Interoperability and Patient Access final rule and the ONC’s Interoperability, Information Blocking, and the ONC Health IT Certification Program final rule were released on the same day to demonstrate a coordinated federal effort. Though not the same program, they are complementary to one another, and both enact a vision from the 21st Century Cures Act. But a Medicare CoP is a very different kind of regulation, and sets the bar for the deliverables a hospital must achieve in order to provide care for Medicare beneficiaries, and to be reimbursed for providing that care.

There is no pressure to comply, as CMS hasn’t shared how non-compliance will be penalized Hospitals have understandably been under significant pressure and resource constraints due to the COVID-19 pandemic. However, CMS has already extended the deadline for this CoP requirement from September 1, 2020 to April 30, 2021 – and hospitals now have less than three months to demonstrate compliance. And although CMS still hasn’t provided guidance on how non-compliance will be penalized, hospitals that fail to fulfill other CMS CoPs face fines and can lose Medicare funding. Though hospitals may not feel the urgency or pressure to comply, it is in their best interests to set in place the infrastructure required to send electronic patient event notifications by the April 30, 2021 deadline.

Fortunately, CarePort customers already have the infrastructure in place to meet all requirements by April 30, 2021. A turnkey solution with a quick implementation timeline, CarePort Interop offers a one-stop shop for guaranteed compliance by CMS’s deadline:

  • Simple set-up process for hospitals
  • No onboarding requirements for post-acute providers or physicians
  • Existing workflow integration with thousands of nationwide providers
  • Integration into every hospital EHR (EHR-agnostic), including Epic (CarePort Interop is now available in the Epic App Orchard marketplace)

Still have questions about what your organization must do to achieve compliance? Reach out – CarePort can help.

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