As part of CMS’s Interoperability and Patient Access Final Rule, a newly-created Condition of Participation (CoP) requires hospitals with an EHR to send electronic patient notifications for patient admissions, discharges and transfers to primary care providers (PCPs), physicians and post-acute providers and suppliers. The requirement goes into effect May 1, 2021.
Since most hospitals contribute their ADT feed to a health information exchange (HIE), hospitals seeking to comply with CMS’s new requirements may be wondering whether their participation in an HIE fulfills the CoPs. Below, we explore why a third-party offering, such as CarePort Interop, provides a more comprehensive solution than an HIE in order to comply with CMS’s requirements.
Identifying – and Notifying – Providers
As stated within the final rule, hospitals must make a “reasonable effort” to notify all applicable physicians and post-acute care providers, which means that efforts to notify providers should focus on circumstances within the hospital’s control. CMS is not asking hospitals to redevelop systems and capabilities, so long as a reasonable effort is made. For example, if a hospital sends a notification but the provider is not capable of receiving a notification via the hospital’s system, the hospital has still made a reasonable effort. In some cases, the practitioner primarily responsible for the patient’s care may be a specialist, such as an endocrinologist or oncologist.
However, HIE registration systems may not have a means to capture and identify the physician primarily responsible for a patient’s care, or have visibility into a patient’s care – at a post-acute facility, for example – prior to a hospital admission, discharge or transfer. CarePort’s interoperability solution offers a provider selection tool directly within the hospital EMR that suggests relevant providers based on data in the CarePort system, or the ability to search and find based on patient-identified information.
To ensure compliance with the patient event notification CoPs, hospitals must be able to reach all providers that have an established relationship with the patient – whether in- or out-of-network, and regardless of geographical location. Though HIEs may have most in-network and in-state providers in their systems, they are often limited in their ability to send notifications to out-of-network or out-of-state providers. Every HIE has different capabilities, and so it is the responsibility of hospitals to determine whether their individual HIE has the ability to fulfill CMS’s patient event notification CoPs. CarePort’s network truly sets its interoperability solution apart from HIEs and other third-party offerings on the market, as it can reach all providers – including in- and out-of-network physicians and post-acute providers – and offers access to 110,000+ post-acute providers (SNF, HHA, LTACH, IRH, hospice), 1,000 hospitals and 850,000 direct-enabled physicians on ONC-certified EHRs.
Further, HIEs can only reach those providers that subscribe to the service. This means physicians and post-acute providers would need to subscribe do so in order to receive its alerts. Subscribing to an HIE presents an extra cost that many post-acute providers may not be willing or able to take on – and defeats the spirit of the rule, and its primary purpose, which is enabling care coordination. More than 100,000 post-acute providers are already using the CarePort platform to receive referrals today, and there are no setup or onboarding requirements for post-acute providers or physicians.
The final rule also emphasizes the importance of near-real time patient event notifications tied to patient admissions, discharges and transfers, as receiving near-real time information is critical to ensuring successful care coordination. Even if providers choose to pay to subscribe to HIE notifications, most alerts are not sent in real-time – decreasing the value of the notification. CarePort’s interoperability solution sends real-time patient event notifications to applicable PCPs, physician groups and post-acute providers, and these real-time notifications can also be tailored to prevent alert fatigue.