CMS E-Notifications CoP: 8 CIO Considerations
The Centers for Medicare and Medicaid Services released its final Interoperability and Patient Access Rule which creates a new Condition of Participation (CoP) requiring hospitals send electronic event notifications, or e-notifications, across the continuum of care. Given that the May 1, 2021 deadline for hospitals to comply with this new CoP is quickly approaching, we’ve created a list of considerations to help CIOs assess requirements and capabilities to ensure compliance. CIOs should consider two critical categories: Data Sharing and Managing Technical Complexity.
“If you are a CIO, you will likely have your hands full, so assessing what work can or should be outsourced to vendors that can meet the prescribed requirements will be important.”
DATA SHARING The new CoP requires hospitals send near real-time e-notifications for inpatient admission, discharge, and transfer events as well as Emergency Department visits to all recipients who need the information for treatment, care coordination, or quality improvement purposes. The recipients fall into three main groups: 1) patient-identified providers, 2) established primary care practitioners, practice groups or entities, and 3) post-acute care providers and suppliers. Important considerations: 1.
How will you ensure appropriate data sharing rights, security, and trust is established between you and the e-notification recipients?
2.
How will you send e-notifications to providers that are located out of state or in different regions of the country?
- Dr. John Glaser,
3.
How will you identify and send e-notifications to post-acute care providers?
Former CIO & CEO
4.
How will you process and manage ongoing e-notification requests from the multitude of providers who need to receive information about their patient’s status?
MANAGING TECHNICAL COMPLEXITY To accurately match patients and effectively route e-notifications to the intended providers and entities requires agile patient attribution and roster processing. Patient attribution and rosters change frequently and vary by recipient type. Important considerations: 1.
How will you accurately match patients to specified notification recipients such as primary care practice groups, ACOs, and post-acute care providers and suppliers?
2.
How will you manage and reconcile frequent patient attribution changes across different notification recipient types?
3.
How will you ensure that notifications are sent in near real-time to intended recipients?
4.
How will establish the needed reporting capabilities to extract and analyze data on-demand for audit purposes?
The May 1, 2021 compliance deadline does not leave a lot of preparation time, PatientPing offers a solution that is fully compliant with the new e-notifications CoP. With a nationwide ADT network and the largest post acute footprint, PatientPing sends over 1M e-notifications per month. As the former CIO of Partners Healthcare, Dr. John Glaser, said, “If you are a CIO, you will likely have your hands full, so assessing what work can or should be outsourced to vendors that can meet the prescribed requirements will be important.”
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