The Route to Compliance. A Simplified Pathway. The Countdown to Compliance for the Centers for Medicare and Medicaid Services Interoperability and Patient Access Rule E-Notifications Condition of Participation Provision is On. Hereâ&#x20AC;&#x2122;s What You Need to Know.
About this eBook The Centers for Medicare and Medicaid Services (CMS) Interoperability and Patient Access Rule was finalized on March 9, 2020 and published to the Federal Register on May 1, 2020. The final rule contains a Condition of Participation (CoP) that requires hospitals, psychiatric hospitals, and Critical Access Hospitals to share event notifications, or e-notifications, with other providers across the continuum of care whenever patients have inpatient or emergency department care events. The compliance requirement will go into effect on May 1, 2021 and adds to the list of CoPs hospitals must fulfill to successfully maintain their CMS certification. Certification is critical for hospitals as it determines whether they can receive CMS payments, which often make up more than 50% of a hospitalâ&#x20AC;&#x2122;s payer mix. To support hospitals across the nation in identifying a compliant solution for sending electronic notifications for inpatient admission, discharge and transfer (ADT), and Emergency Department (ED) presentation and discharge, this is part one of an eBook series that will break down the guidance detailing what data need to be shared, to whom you need to send data, and the single solution that can guarantee full e-notification CoP compliance. This eBook is an interactive publication, simply look for links to navigate, play videos, download PDFs and more!
Your Roadmap to E-Notifications CoP Compliance with PatientPing No matter where you are on this journey, we’re here to help guide you every step of the way! This is part one of a four-part eBook series that will feature guidance to help hospital executives and CIOs understand the pathway to compliance. Here’s what this eBook outlines and a preview of the upcoming eBooks within our series!
WE ARE HERE! PHASE ONE
Research and Planning Your Trip
Getting on the Road
On the Highway to Compliance
Now That We’ve Arrived, What’s Next?
6 â&#x20AC;¢ THE ROUTE TO CoP COMPLIANCE. A SIMPLIFIED PATHWAY.
WHATâ&#x20AC;&#x2122;S INCLUDED IN THIS EBOOK
Part One: Researching and Planning Your Trip SECTION 1:
Getting Familiar with the E-Notifications CoP
Where Our Community Stands
Why and How You Need to Comply SECTION 4:
CoP Compliance Resources
Route - the Compliance Solution
SECTION 1: OVERVIEW
Getting Familiar with the E-Notifications CoP
The new CMS Condition of Participation requires all hospitals, psychiatric hospitals, and critical access hospitals utilizing an electronic medical records system or other electronic administrative system that is conformant with the content exchange standard HL7 v2.5.1 to make a reasonable effort to send real-time electronic notifications: AT: the point of inpatient and observation admission, discharge, transfer and at emergency department presentation or discharge TO: every patientâ&#x20AC;&#x2122;s established PCP, established primary care practice group or entity, other practitioners/practice groups/entities identified by the patient as primarily responsible for his or her care, and applicable post-acute providers who need to receive notification for treatment, care coordination, or quality improvement purposes CONTAINING: at minimum, patient name, treating practitioner name, and sending institution name
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“Hospitals will need the ability to manage and respond to all these different requests... it could quickly become overwhelming and they must prepare to minimize administrative and technical burdens associated with being in compliance.” — Dr. John Glaser, Former CIO & CEO
SECTION 2: WHERE OUR COMMUNITY STANDS
Survey Results To gauge hospital CIO awareness for e-notifications CoP compliance, PatientPing recently conducted a survey in May and June of 2020. Targeted to focus on U.S. hospitals and health systems only, the survey elicited responses from CIOs and executives working in IT, compliance, and HIM functions. According to the results, we found that:
of respondents were familiar with the new e-notifications CoP
of respondents are less than familiar with the new e-notifications CoP
This is a stark contrast as the compliance deadline is a few months away
of respondents believed that they could currently handle external e-notification requests from community providers, which means, to be compliant, they will not need a new solution.
10 â&#x20AC;˘ THE ROUTE TO CoP COMPLIANCE. A SIMPLIFIED PATHWAY.
2/3 of CIOs surveyed are less than confident that their organization will be compliant by the May 1, 2021 deadline
90% of respondents agreed that it is a priority for their organization to ensure compliance with the e-notifications CoP
In addition, the executives somewhat agreed that their current EHR vendor or HIE could ensure e-notifications CoP compliance, however, the reality is that most do not have all the appropriate functionality at this time to ensure CMS reimbursements. The compliance requirement adds to the list of CoPs hospitals must fulfill to successfully maintain their CMS provider agreement. The CMS provider agreement is critical for hospitals as it determines whether they can receive CMS reimbursements, which often make up more than 50% of a hospitalâ&#x20AC;&#x2122;s payer mix. To receive or maintain certification, hospitals must meet the CoP compliance requirement of sharing e-notifications with other providers across the continuum of care whenever patients have inpatient admissions, discharges and transfers, and emergency department presentations and discharges. Hospitals across the country are in need of a solution to send electronic event notifications in real time to community providers that require notification of the patientâ&#x20AC;&#x2122;s status for treatment, care coordination, or quality improvement purposes. They also must consider a solution that can scale their services to handle the potential volume of requests and associated roster processing required to fulfill in and out of state post-acute and primary care group e-notification requests. PATIENTPING.COM
SECTION 3: WHY AND HOW YOU NEED TO COMPLY
Importance of the E-Notifications CoP and Why Hospitals Must Comply The Threat of Losing CMS Certification and Payments CoPs are the minimum requirements that CMS sets to protect the health and safety of patients and to improve quality of care. They are critical to all aspects of hospital operations and address policies and procedures related to infection control, staffing ratios, medical records documentation, compliance with applicable federal, state, and local laws, and patient’s rights, among others. CoPs are the provisions that State Survey Agencies or Accreditation Organizations audit during their unannounced surveys. Deficiencies with any CoP can lead to certification termination and will set off a cascade of time-bound termination and corrective action procedures. The threat of losing CMS certification and payments is significant as Medicare represents approximately 40% of a hospital’s payer-mix and Medicaid usually over 20%. All CoPs are formalized as part of the Code of Federal Regulation and CMS has the authority to amend existing CoPs and to create new CoPs.
The threat of losing CMS certification and payments is significant as Medicare represents approximately 40% of a hospital’s payer-mix and Medicaid usually over 20%
12 • THE ROUTE TO CoP COMPLIANCE. A SIMPLIFIED PATHWAY.
COMPLIANCE CHECKLIST What data need to be shared? 1. Send real-time e-notifications containing patient name, treating practitioner name, and sending institution name at the point of patient admission, discharge, and transfer for ED, inpatient, and observation patients 1a. Following data elements encouraged but not required: chief complaint, medication profile, discharge disposition, and diagnoses To whom do you need to send data? 2. Send e-notifications to patient-identified practitioners 2a. Established primary care practitioners 2b. Other practitioners primarily responsible for a patient’s care 2c. Named treating providers with signed patient consent for patients in psychiatric units 3. Have the ability to meet e-notification requirements for all recipients who need to receive notifications for purposes of treatment, care coordination, and quality improvement 3a. Entities affiliated with a patient’s primary care practitioner including: • Primary Care Practices • Accountable Care Organizations • Federally Qualified Health Centers • Physician Organizations • Independent Physician Associations 3b. Post-acute services providers and suppliers with whom the patient has an established care relationship prior to admission or to whom the patient is being transferred or referred including: • • •
Skilled Nursing Facilities Home Health Agencies Hospices
DOWNLOAD OUR COMPLIANCE CHECKLIST
This compliance checklist has been produced by PatientPing, Inc. for educational purposes only.
SECTION 4: RESOURCES
The Pathway to E-Notifications CoP Compliance: Getting Up to Speed What CIOs and Hospital Leaders Need to Know PatientPing is actively working to help guide hospitals down the path of compliance. Our resources will detail CoP requirements and provide considerations to take into account when selecting a compliance solution. In this section, you’ll find a compilation of blogs, videos, webinars, and press coverage.
CMS E-Notifications CoP: 8 Considerations CIOs Should Consider Two Critical Categories: Data Sharing and Managing Technical Complexity 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? 3. How will you identify and send e-notifications to post-acute care providers? 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?
14 • THE ROUTE TO CoP COMPLIANCE. A SIMPLIFIED PATHWAY.
“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.” — Dr. John Glaser, Former CIO & CEO
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 you establish the needed reporting capabilities to extract and analyze data on-demand for audit purposes? DOWNLOAD PDF
SECTION 4: RESOURCES
Webinars + Videos
Listen & Learn: Frameworks to Assess Gaps Organizations May Have With Compliance and the Considerations to Take Into Account When Selecting a Compliance Solution Watch the “CMS’s Interoperability & Patient Access Rule: E-Notifications Condition of Participation” webinar for more on the following: • • • •
All requirements included within the rule Frameworks to assess gaps organizations may have with compliance Considerations to take into account when selecting compliance solutions An e-notification solution that guarantees compliance by the May 1, 2021 deadline
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The Impact on Providers With the CMS and ONC rules surrounding interoperability and patient access finalized, Dr. John Glaser shared his thoughts on the need for information sharing, the impact these rules will have on providers, as well as how organizations can succeed and comply.
“Another opportunity of added information sharing is an improved understanding of the patient context with a clinician at the point of care. Providing clinicians and care team members with more information and patient content, not only improves clinical decision making and efficiency but allows for more attention to be focused on the patient.” — Dr. John Glaser, Former CIO & CEO PATIENTPING.COM
SECTION 4: RESOURCES
Washington Debrief: Navigate the Details of CoP with Digital Leaders Listen to the “CHIME & PatientPing Webinar: E-notifications Condition of Participation” with Jay Desai, CEO of PatientPing, Dr. John Glaser, Former CEO & CIO, Russell Branzell, President & CEO of CHIME, and Mari Savickis, VP of Public Policy at CHIME, to learn more about the CoP and how hospitals can comply by the May 1, 2021 deadline. CLICK HERE TO LISTEN TO THIS WEBINAR
“What ADT notifications and specifically data are doing is providing real-time visibility into health system strain. Emergency Rooms (ERs), in-patient care settings and ICUs are getting overloaded. This is a real-time tool to be able to see the extent to which ERs have overcrowding for COVID-19 diagnoses or overall to be able to support the rising number of folks that will need emergent and intensive care.” — Jay Desai, CEO of PatientPing 18 • THE ROUTE TO CoP COMPLIANCE. A SIMPLIFIED PATHWAY.
“Hospitals will need the ability to manage and respond to all these different requests. It could quickly become overwhelming and they must prepare to minimize administrative and technical burdens associated with being in compliance. Now, it’s critical to note that the population of those potentially making requests is not just within their city, state, or region but could be across the entire country.” — Dr. John Glaser, Former CIO & CEO
How Hospitals Can Succeed Dr. John Glaser shares what hospitals need to know about the rule, and how they can best succeed and comply.
SECTION 4: RESOURCES
HIStalk Interviews Jay Desai, CEO of PatientPing HIStalk sat down with Jay Desai, CEO of PatientPing, to discuss the recently finalized CMS and ONC rules around interoperability and patient access. Jay discusses how the rules will impact providers, what they’ll need to do to comply, and the role his organization will play in helping them to succeed. READ FULL INTERVIEW
“The CMS and ONC operability rules are totally groundbre CMS and ONC had a lot of hard decisions to make, and I’ care, care coordination, and quality improvement. Many ho in place. We think this will create a broader national frame excited about that. We’re excited to su
— Jay Desai, CE
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PatientPing CEO, Jay Desai, speaks with HealthSystemCIO On March 9, 2020 HHS and ONC published the long-awaited 21st Century Cures Interoperability Final Rule. While the interoperability rule may have been the most hotly debated part, an important section requiring hospitals and health systems to send electronic notifications to other healthcare providers when a patient is admitted, discharged, or transferred could have the greatest impact on care quality. In this interview, Jay breaks down the rule and offers advice on how CIOs can get into compliance for Condition of Participation. READ FULL INTERVIEW
eaking. I’m excited about what they will do for patient care. ’m impressed by their commitment to supporting patient ospitals have been thinking about this and putting solutions ework under which this information is going to flow. We’re upport it and be part of the solution.”
EO of PatientPing
SECTION 5: HOW PATIENTPING CAN HELP
The Route to CoP Compliance PatientPing Has Launched Route - the Simplest, Most Comprehensive Solution to Guarantee That Electronic Patient Event Notifications are Processed in a Secure and Compliant Manner Built on PatientPing’s trusted national e-notifications network, Route alleviates hospitals’ compliance IT and data-sharing burdens. Route seamlessly delivers e-notifications to providers as identified by patients as well as to requesting community provider groups. Route manages all the complexities involved with sending required e-notifications, from executing data share agreements with all e-notification recipients, to managing and executing the frequent, real-time changes to a diverse array of patient roster types to track patient/provider attribution.
PatientPing is the Nation’s Leading ADT National Network 5000 + Post-Acute Facilities
1,000+ hospitals and 5,000+ post-acute facilities rely on PatientPing to deliver their e-notifications today
National network covers 43 million patients and has processed 135 million patient ADT events
300+ Physician Orgs
Accurate patient matching algorithm - ONC certified 99.99% match rate
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Proven and scalable real-time processing of e-notifications
Streamlined onboarding - no software to install or upgrades necessary
Features of Route 1. Route Handles All E-Notifications to Patient-Identified Providers
Providers Identified During Hospital Encounter Patient (or patient record) identifies what provider(s) should be notified in the hospital EHR/registration system
PatientPing Matches the Identified Provider to Our National Directory
PCPs and Other Identified Providers Receive Direct Messages
Patient encounter data, including patient-identified provider (NPI and other information), is processed and merged with PatientPingâ&#x20AC;&#x2122;s national database
E-notifications are sent to the patient-identified provider in real time and are logged for audit reporting
SECTION 5: HOW PATIENTPING CAN HELP 2. Community Provider Groups Request E-Notifications Through the Route Requester Portal Using a Simple, Secure Form on the Hospital’s/Health System’s Website
The Route Portal then captures and fulfills all requests and provides an audit trail
Community providers submit requests
PatientPing representative validates and triages requests for fulfillment
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E-notifications are sent in real time to valid requesting community providers
3. Recipients of Route E-Notifications Can Choose Their Desired Notification Format
4. Route Provides Full Audit trail of E-Notifications Receipt, Ensuring Transparency, Security and Visibility into Data Sharing
Searchable by unique patient identifier to demonstrate compliance during CMS survey random patient record reviews
At-a-glance view of data sharing at a national level
Includes written Route policies and procedures document for use in CMS surveys
“One significant opportunity of added interoperability is better insight into patients’ transitions of care. Poorly managed transitions not only cause undue stress on the patient and their family, but take a toll on the entire system’s finances. As patients move from care setting to care setting, the sharing of information about that patient’s care is critical so that important elements of the care plan are not missed.” — Dr. John Glaser, Former CIO & CEO
SECTION 5: HOW PATIENTPING CAN HELP
Reduce IT Complexity Offload the burden of managing all incoming provider requests for e-notifications via the Route Requester Portal Reduce IT burden as Route handles all outbound ADT data feeds to both providers and HIEs / intermediaries Hospitals only need to maintain one outbound ADT feed Receive a complete audit trail of all e-notifications sent for CMS survey and security peace of mind Immediate compliance with over 1,500 post-acute providers and primary care groups who receive PatientPing e-notifications today
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Route Guarantees CoP Compliance Route Ensures Complete E-Notifications CoP Compliance and Offers Increased IT Operational Efficiency
E-Notifications for requesters on PatientPingâ&#x20AC;&#x2122;s national network
Requester Portal to manage all incoming e-notification requests from community providers
E-notifications to PCPs and other patient-identified practitioners
Audit reporting with policies and procedures documentation
Intermediary ADT data management to increase operational efficiency
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