PART TWO: Your Roadmap to Compliance for Patient-Identified and Provider-Requested E-Notifications

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EBOOK

PART TWO

Your Roadmap to Compliance for Patient-Identified and Provider-Requested E-Notifications The Countdown to Compliance for the Centers for Medicare and Medicaid Services’ Interoperability and Patient Access Rule E-Notifications Condition of Participation.

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About this eBook The Centers for Medicare and Medicaid Services’ (CMS) Interoperability and Patient Access E-Notifications Condition of Participation (CoP) deadline is quickly approaching for hospitals and health systems. To ensure compliance with the CoP, IT and compliance executives are actively assessing the rule’s requirements and researching solutions to send real-time e-notifications at the point of inpatient, Admissions, Discharges and Transfers (ADT), and emergency department (ED) presentations and discharges. Questions many are asking are: • • • •

What does the rule actually entail? To whom must hospitals send e-notifications? Can EHR vendors manage this? Are hospitals compliant if they use an HIE?

To help hospitals understand the requirements to meet the May 1, 2021 deadline, this eBook breaks down the rule and examines its key clauses, discusses how hospitals can fulfill requests for provider-requested notifications, and covers how post acutes, Accountable Care Organizations (ACOs), and care teams can prepare to receive electronic e-notifications from hospitals as patient-identified practitioners and/or requesting community providers. This eBook is an interactive publication, simply look for links to navigate, play videos and more!


WHAT’S AHEAD

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 two 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.

PHASE ONE

WE ARE HERE!

Research and Planning Your Trip

PHASE TWO

Getting on the Road


PHASE THREE

On the Highway to Compliance

PHASE FOUR

Now That We’ve Arrived, What’s Next?


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WHAT’S INCLUDED IN THIS EBOOK

Part Two: Getting on the Road to Compliance SECTION 1:

Understanding the E-Notifications CoP SECTION 2:

Fulfilling Provider-Requested Notifications SECTION 3:

The Potential Role of EHRs and HIEs SECTION 4:

Preparing Providers / Care Teams SECTION 5:

Guidance for the Compliance Road Ahead SECTION 6:

CMS E-Notifications Compliance Solution

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SECTION 1: UNDERSTANDING THE E-NOTIFICATIONS CoP

What You Need to Know A Quick Snapshot of the Rule In March of 2020, CMS finalized the new Interoperability and Patient Access Rule, which creates a new CoP that requires hospitals, psychiatric hospitals, and critical access hospitals to share electronic ADT-based e-notifications with other providers across the care continuum whenever patients have inpatient or emergency department care events. The rule was designed to help hospitals better serve their patients through coordinated and collaborative care and prevent patient readmission. To summarize, hospitals utilizing an EHR system or other electronic administrative system that is conformant with the content exchange standard HL7 v2.5.1 must 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 patient’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 With the May 1, 2021 compliance deadline nearing, there is still confusion in the market regarding interpretation of the rule and around hospital solutions available to address the e-notifications CoP. In this eBook, we clarify the reasonable effort hospitals must make to send real-time e-notifications and their responsibility to respond to provider-requested e-notifications.

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For a more in-depth understanding of how hospitals can achieve full compliance requirements and for key considerations and a readiness checklist, PatientPing’s Vanessa Kuhn, Director of Policy, authored an executive white paper: Electronic E-Notifications CoP: Understanding and Meeting Compliance Requirements DOWNLOAD THE WHITE PAPER

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SECTION 2: PROVIDER-REQUESTED NOTIFICATIONS

Fulfilling Provider-Requested Notifications The Need for Post Acutes and Primary Care Groups to Request and Receive E-Notifications on Behalf of Their Patients To determine the providers with established care relationships that need to receive e-notifications based on CMS requirements, hospitals or their intermediary need two distinct capabilities. They include: 1. Ability to collect patient-identified provider information at the point of care 2. Ability to obtain care relationship information from providers through a patient roster and notification request process The first capability allows hospitals to determine any providers with whom the patient wants their information shared by giving patients the ability to identify their providers at the point of care. The second allows hospitals or intermediaries to determine any additional practitioners, practice groups/entities, or post-acutes that need to receive notifications for treatment, care coordination, or quality improvement activities. The roster and notification request process allow providers to identify their care relationships through a roster, such as a patient panel or census list, and receive e-notifications based on hospital care events that match to patients on those rosters. Having both of these capabilities gives hospitals the ability to determine the required set of providers that need notifications, thereby eliminating e-notification gaps that would lead to non-compliance. For health systems with large provider and post-acute referral networks, hospitals must send e-notifications to community-based providers that have established care relationships with patients, including: primary care practitioners, Federally Qualified Health Centers (FQHCs), other entities identified by the patient as primarily responsible for their care, and post-acute providers (skilled nursing facilities, home health agencies, etc.). This information is needed for treatment, care coordination, or quality improvement activities. Therefore, identifying which providers have established care relationships is critical and requires that hospitals, or their intermediary, possess the capabilities to collect patient-identified provider information at the point of care; and obtain care relationship information from providers through a patient roster and notification request process.

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ACOs

ED

As part of the e-notifications CoP, CMS mandates that hospitals must make a reasonable effort to send these provider-requested e-notifications in real-time. To best understand how to define the “reasonable effort� hospitals should be making to comply with the e-notifications CoP, Vanessa Kuhn, Director of Policy, delves into what hospital executives need to know about the rule and provider-requested e-notifications.

READ HER ARTICLE

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SECTION 3: THE POTENTIAL ROLE OF EHRs AND HIEs

EHRs and HIEs: What Hospitals Should Consider The Risk of Not Connecting Requesters Across Care Settings and Across Geographies PatientPing surveyed hospital CIOs across the nation and found that a majority of respondents believe they can currently meet the needs to send patient-identified notifications to demonstrate reasonable effort. This includes believing that their existing direct notification capabilities meet minimum reasonable effort and that they do not need to add any other connections or solution capabilities. With this approach, hospitals are entrusting HIEs and EHRs with compliance that if proven otherwise could lead to substantial financial penalties. Consider that e-notifications must be sent to all providers that: have an established care relationship with the patient; are able to receive e-notifications; and that need the information for treatment, care coordination, or quality improvement purposes. These requesters will be located across care settings and across geographies (local care community and out-of-state). For a large hospital or hospital system, this could mean routing thousands of real-time e-notifications/ADT messages to providers across the country that are beyond the reach of local or regional HIEs. The ability of local HIEs to connect providers across state lines is potentially limited. For example, a high-risk patient who travels from New Hampshire to Texas every winter will need their ADT data shared with their providers located in their current state of residency. If the New Hampshire and Texas hospitals rely only on their local HIE, required notifications that must be sent to the out-of-state providers expose that hospital to a risk of non-compliance. Some hospitals’ EHR service providers may be able to help with this, but direct messaging functionality for inpatient admit and ED presentation events carved into the CoP rule will need to be enabled. Meaningful use requirements only specify notifications upon inpatient discharge events when needed; therefore, most EHRs currently do not have functionality to send e-notifications at ED presentation and inpatient admit active and available to customers.

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Questions to Ask Your EHR EHRs have a critical role to play in enabling interoperability to support policy goals. However, like all software, EHRs are limited by their functional capabilities, adoption within and outside the provider community, and delivery/support model. Unlike the CMS Meaningful Use Program, there are no accompanying set of certification requirements or responsibilities imposed on the EHR (or for that matter, an HIE) in order to meet the e-notifications CoP requirements in the CMS Interoperability and Patient Access Rule. The responsibility is entirely on the shoulders of the health system. As such, it is important that health systems sufficiently evaluate the CoP support being developed by their EHRs to ensure that they successfully comply with this important rule. To start, consider asking these questions. CLICK HERE TO READ OUR RECOMMENDATIONS

Questions to Ask Your HIE HIEs can help with e-notifications compliance, but the hospital is ultimately responsible for ensuring the intermediary it uses is a fully compliant solution. Depending on the HIE’s capabilities, post-acute network cpverage, and the hospital’s own geographic reach, there might be gaps that need to be filled. Asking the following questions will help hospitals identify such gaps. CLICK HERE TO READ OUR RECOMMENDATIONS

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How PatientPing Can Help PatientPing offers the full compliance solution—including leveraging your EHR’s push-messaging functionality where desired—in order to ensure that notifications are delivered to all the eligible recipients of the CMS CoP rule. PatientPing enables health systems to receive and process notifications requests through a touchless software and service experience, dynamically and automatically attribute patients to their community providers in real-time, and then deliver notifications through a variety of means, including secure web portal, on-demand data download, push messaging, and other integrations.

CONTACT US

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PatientPing is the Nation’s Leading ADT National Network 5000 + Post-Acute Facilities

300+ Physician Orgs

1000+ Hospitals

National network covers 43 million patients and has processed 135 million patient ADT events

Accurate patient matching algorithm - ONC certified 99.99% match rate

Streamlined onboarding - no software to install or upgrades necessary

Proven and scalable real-time processing of e-notifications

PatientPing’s existing national network already includes thousands of providers spanning the country, and it continues to expand. In addition, PatientPing’s commitment to managing and auditing provider requests for e-notifications addresses the ability for post acutes to receive ADT information at no cost, eliminating any real or perceived barriers that could jeopardize compliance with the CoP requirements.

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SECTION 4: PREPARING PROVIDERS / CARE TEAMS

How Practitioners, Care Teams, and Post Acutes Can Prepare for the E-Notifications CoP Accelerating the Ability to Receive Information on Shared Patients Receiving e-notifications gives eligible practitioners, care teams, and post acutes added transparency about their patients’ hospitalizations and improved insight into when transition of care processes need to be initiated. The additional encounter information can also help streamline workflows and allow for more timely patient follow-ups. Practitioners, care teams, and post acutes should consider how to effectively use and incorporate the additional information into workflows and care transition planning. For those participating in value-based care arrangements, e-notifications can further support utilization and total cost of care management efforts.

Here are some steps to support organizational readiness: Identify hospitals with strong referral patterns and/or high utilization: Practitioners, care teams, and post acutes should identify those hospitals, local hospitals, and specialized hospitals that are strong referral partners and those that see high patient utilization. Because eligible practitioners, care teams, and post acutes can request e-notifications on shared patients from any CoP impacted hospital, knowing the scope of hospitals will be important. Understand options to receive e-notifications: Eligible providers will need a mechanism to receive e-notifications as a necessary precondition to make e-notifications requests from hospitals or from a hospital’s selected intermediary. Options may include a third-party portal, setting up an EHR integration, using direct messaging, or leveraging a hospital’s API.

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Consider implementation and workflow impacts: Providers should consider how e-notifications will be used effectively across the organization, from workflow to staffing. E-notifications are intended to support care coordination activities. Organizations should consider change management needs to help optimize the impact of e-notifications. Plan for e-notifications based on panel or census changes: Determine how often patient panels or census change and how such changes will impact their desired e-notification scope such as daily or weekly e-notification request changes. As practitioners, care teams, and post acutes plan for e-notifications, they should consider how they can receive e-notification on their desired set of patients.

Want to learn more? Check out the video, “The CMS Proposed Interoperability & Patient Access Rule Series with Dr. John Glaser: How Physicians & Post-Acutes Can Prepare.” Dr. John Glaser, former CIO, discusses CMS’s Interoperability & Patient Access Rule and shares what physicians and post-acutes need to know about the rule, and how to succeed and comply.

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SECTION 5: GUIDANCE FOR THE COMPLIANCE ROAD AHEAD

PatientPing’s Executive Insight to Guide Hospitals on Their Road to Achieving E-Notifications Compliance Resources for Understanding the CMS E-Notifications CoP To get on the road to compliance, PatientPing’s team is spreading awareness and creating clarity for hospital executives to better understand the e-notifications CoP. Our resources provide insight around misconceptions related to the rule, providerrequested notifications, CoP requirements, and detail the only solution that can guarantee e-notifications COP Compliance, Route. PATIENTPING ARTICLE

Clarifying 5 Misconceptions about CMS’s E-Notifications Condition of Participation Vanessa Kuhn details survey results fielded in June 2020 asking hospital CIOs and compliance executives about their perceptions of the new e-notifications CoP. Notably, the survey exposed several misconceptions about the new requirements and highlighted some inaccurate assumptions. To help CIOs and compliance leaders understand the full CoP requirements and the capabilities needed to meet them, Vanessa addresses the main misconceptions in her article and offers additional information to increase awareness and readiness.

“Just under 50% of respondents stated that they have the capabilities in place to address all external requests from other community-based providers for their attributed patients. Meeting these requests will require hospitals or their intermediary to manage patient rosters and match patient care events to those rosters which then trigger notifications. Because care relationships can change daily, especially in the post-acute setting, patient attribution information from rosters needs to be updated accordingly, which can increase the technical complexity of managing e-notifications.”

READ FULL ARTICLE

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HISTALK ARTICLE

CMS’s E-Notifications Condition of Participation: Three Topics to Know PatientPing CEO Jay Desai writes about helping hospitals prepare for the e-notifications CoP by revealing three key areas that need more awareness. “The fact that CMS used its most consequential regulatory lever, a CoP, to create the new e-notification requirement underscores the importance the agency places on increasing provider access to needed information. Hospitals should answer how they or their third-party intermediary solution will comply with the following requirements: □ Identify and send e-notifications to post-acutes □ Meet cross-regional provider notification needs □ Ensure appropriate data sharing rights, security, and trust □ Send notifications in real time □ Manage continuous provider-patient relationship changes □ Demonstrate compliance to meet survey requirements □ Ensure community-based providers have excellent user experience □ Meet compliance by the May 1, 2021 deadline”

READ FULL ARTICLE

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SECTION 5: GUIDANCE FOR THE COMPLIANCE ROAD AHEAD

HIT CONSULTANT ARTICLE

How ADT-Based E-Notifications Can Enable Better Safety for COVID-19 Patients By Jay Desai, CEO of PatientPing

“Protecting patient safety and providing appropriate treatment is especially urgent during a crisis like COVID-19 when resources are limited and staff is stretched. E-notifications allow hospitals that treat COVID-19 patients to more rapidly get in touch with a patient’s other providers and obtain important medical histories to help guide treatment and clinical decision-making. Traditional exchange of data facilitated by phone calls, faxes, or labor-intensive data searches can introduce treatment delays, unnecessary or harmful interventions, and frustrations for providers. The faster information can be exchanged and a patient’s history is known by the hospital care team, the easier it is to effectively and safely treat the patient with the most appropriate interventions.” READ FULL ARTICLE

HLTH GOLIVE WEBINAR

Liberating Patient Data through Interoperability With the onset of new CMS and ONC rules around interoperability impacting how to share and utilize data, it is crucial for all stakeholders to know where they fit in the data chain and how to best comply. On top of understanding the regulations, the industry has to be ready to embrace greater innovation to further liberate patient data to allow for more informed care decisions and assist patients in managing their own health. For example, where are the breakthrough solutions focused on interoperability making

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VIDEO

Hear from Dr. John Glaser

Dr. Glaser shares his thoughts on the need for information sharing, the impact these rules could have on providers, as well as how organizations can prepare to succeed once the rules are finalized.

an impact now? To help answer those questions, Jitin Asnaani, PatientPing’s Head of Partnerships, joined our partner Lyniate for the HLTH’s Go LIVE webinar, “Liberating PatientData Through Interoperability.” Watch the recording for more information on the new CMS and ONC rules around interoperability by clicking the button below:

WATCH THE WEBINAR

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SECTION 5: GUIDANCE FOR THE COMPLIANCE ROAD AHEAD

PATIENTPING ARTICLE

Important Questions to Ask Your EHR 1) Will my EHR meet the functional requirements of the rule? EHRs are investing in improving direct messaging functionality, which is likely to be a worthwhile investment even beyond the requirements of this rule. However, what tools will your EHR deliver in order to help you service and fulfill notifications requests from the primary care and post-acute community, as per the rule? 2) Will my EHR enable me to fulfill the business obligations created by the rule? The CoP requires the ability to provide notifications to a broad variety of primary care and post-acute stakeholders- not just in your community, but wherever your patients encounter them nationwide. Such entities include, for example, SNFs, home health agencies, hospice facilities, ACOs, FQHCs, and a wide variety of other post-acute and primary care entities. Interoperability enablers such as hospital-based EHRs and regional HIEs are often able to integrate with other acute hospitals, but generally do not have the integrations or business model to adequately serve the post-acute or ambulatory spectrum, certainly those that cross state borders. When they do so, they often impose untenable costs on those community providers. 3) Will my EHR reduce the administrative and operational burdens on my team? EHRs are building software in support of the rule. However, as with all regulation, there is an associated commitment of human resources needed in order to meet the requirements. For example, as patients of your institution have encounters with primary care and post-acute entities nationwide, those institutions may choose to request notifications from your institution for those mutual patients. To fulfill those requests, the requesters need to be

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vetted and appropriately contracted, and their relevant patient rosters need to be collected, and finally fulfilled through event notifications. The roster process alone is one of the most complicated aspects of serving provider requests. Building good software to enable these tasks comes only through experience, and most EHRs are not versed in the complexities of managing provider requests and the enormous variety of rosters; often, the EHR solution may entail a manual upload of the patient census into the registration or record system, or even require unique manual data entry for each admission and discharge. Stepping back, while well-designed software can be a helpful asset in achieving these tasks, the requester validation and contracting process will inexorably entail a human service component as well, which the EHR may not be able to provide. 4) Will my EHR sufficiently support a CMS audit with the requisite tools and documentation? The EHR will likely provide a log of all the messages pushed. However, to succeed with a CMS audit, hospitals need to have policies, processes, and systems in place to identify a patientprovider relationship in the acute, post-acute, ambulatory and community space, then proactively send an e-notification. As outlined in the final rule, the e-notification requirement will fall under the Medical Records Services CoP (42 CFR §482.24 as subpart (d)) and will require proof of e-notifications for a random record pull. Capabilities important for compliance include: • View and download all e-notifications sent by patient ID • Download a list of provider requests received for e-notifications • Document all locations where e-notifications were sent

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SECTION 5: GUIDANCE FOR THE COMPLIANCE ROAD AHEAD 5) Will my EHR reflect well on my organization’s reputation with the primary care and post-acute providers in our community? CMS recognizes that all hospitals are critical in care transitions, that more information will enable care coordination, and that the existing information sharing is insufficient. The intent of this CoP is to support care coordination and interoperability across the continuum to improve outcomes, make information available for treatment, care coordination, and quality improvement, and to eliminate barriers to information sharing. While user experience is not strictly a requirement of this CoP, in practice effortless integrations, uncomplicated collaboration mechanisms, and seamless access to patient-provider relationship information should be part of any hospital’s consideration. Indeed, several regional and national healthcare organizations have identified end-user experience/satisfaction as a minimum requirement for their e-notifications vendor selection.

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Important Questions to Ask Your HIE 1) Can HIEs meet the compliance deadline? The CoP requires e-notifications be sent at the time a patient event occurs to any established practitioner, practice group/entity, or post-acute regardless of their geographic location. Hospitals should consider that most HIEs send notifications only within their state or regional borders and may not have the required dynamic roster or census capabilities developed to service in the full range of providers as required by the CoP. Such limitations would prevent notifications to be sent in real time on behalf of the hospital to all providers that must receive them. Since hospitals will ultimately be held accountable for meeting compliance requirements, even 24

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if they use an intermediary, hospital leaders should evaluate their HIE’s capabilities and assess if they might face non-compliance risk and undue exposure. Encourage your members to ask the HIE: 1. Can you guarantee compliance for the e-notifications CoP by the May 1, 2021 deadline? 2. Are you prepared to meet unique state regulations for e-notifications for each requester? 2) Will the HIE provide audit reporting sufficient for compliance/audit? Reporting on every e-notification by patient record is believed to be just as important as connection scalability for this rule. As outlined in the final rule, the e-notification requirement will fall under the Medical Records Services CoP (42 CFR §482.24 as subpart (d)) and will require proof of e-notifications for a random record pull. PatientPing’s audit reporting is built with a CoP audit in mind and includes: • E-notification by patient ID • Requests received for e-notifications • Locations of where e-notifications were sent 3) Does the HIE have the resources/capital to guarantee all the necessary post-acute connections in your area? And what about the out-of-state requests? HIE’s coverage of post-acute providers in your area may be lacking. If the post-acute provider is not on the HIE network, they can’t receive alerts. How quickly can the HIE bring new post-acute organizations on to their network? And, as mentioned previously, most HIEs send notifications only within state or within regional borders. Sending e-notifications across state lines or even nationally is likely not possible with an HIE-only solution.

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SECTION 5: GUIDANCE FOR THE COMPLIANCE ROAD AHEAD PATIENTPING ARTICLE

Defining “Reasonable Effort” for Hospital CMS E-Notifications Compliance Vanessa Kuhn, Director of Policy, delves into what hospital executives need to know about the rule and explores one ambiguous provision in particular–namely what constitutes hospitals making a “Reasonable Effort” to send e-notifications to patient-identified practitioners and to requesting community providers. With only a few months until the compliance deadline goes into effect for the new electronic event notifications Condition of Participation (CoP), hospital executives and IT teams are actively seeking solutions to ensure compliance. As of May 1, 2021, hospitals will be required to send electronic event notifications, or e-notifications, to patients’ other community-based providers for purposes of improving treatment, care coordination, and quality improvement activities. The CoP was finalized as part of the Centers for Medicare and Medicaid Services (CMS) Interoperability and Patient Access Rule (85 FR 25602). While CMS sought to give hospitals flexibility in implementing the new CoP, some of the provisions can be interpreted as being ambiguous if not anchored back to the intent, goals, and comments provided by CMS. This has resulted in some confusion in the market about the CoP requirements. This article will discuss what hospital executives need to know about the rule and explore one ambiguous provision in particular–namely what constitutes hospitals making a “Reasonable Effort” to send e-notifications to patient-identified practitioners and to requesting community providers. Understanding the Rule First, let’s take a deeper dive into the CMS Interoperability and Patient Access Rule. The final rule was published on May 1, 2020 and in light of COVID-19, the compliance deadline for the new CoP was extended until May 1, 2021. The CoP applies to all hospitals, psychiatric hospitals, and Critical Access Hospitals and requires all hospitals utilizing an electronic health record (EHR) system or other electronic administrative system (which is conformant with the content exchange standard HL7 v2.5.1) to make a reasonable effort to send real-time e-notifications at inpatient Admit, Discharge and Transfer (ADT) and emergency department (ED) presentation and discharge to patients’ other community-based

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providers. Hospitals have the option to use a third-party intermediary to manage and send all required e-notifications or build their own in-house solution. In particular, the e-notifications must be sent to patients’ other established providers that need the information for treatment, care coordination, or quality improvement activities. These other established providers fall into three categories, namely a patient’s: • Established primary care practitioner, established primary care practice group or entity (e.g. physician organizations, Federally Qualified Health Centers, accountable care organizations, etc.) • Other practitioners, practice groups or entities identified by the patient as primarily responsible for their care. • Applicable post-acute service providers and suppliers (e.g. skilled nursing facilities, home health agencies, etc.) Notification recipients may be specified at the point of care by patients or may make their established care relationships known to the hospital, or its intermediary, through notification requests on their patients. Notification recipients and requesters will be located across care settings and across geographies (local care community and out-of-state). For a large hospital or hospital system, this could mean routing thousands of real-time e-notifications/ADT messages to providers across the country that may be beyond the reach of local or regional HIEs. Where the Confusion Lies: Provider-Requested Notifications For hospitals to better serve their patients through coordinated and collaborative care, CMS intended for hospitals to send e-notifications to all those providers that need them. Specifically, the final rule states, “...our revised regulation text states that hospitals must send notifications to those recipients that need to receive notifications of the patient’s status for treatment, care coordination, or quality improvement purposes” (85 FR 25598). As mentioned, hospitals are held to a “Reasonable Effort” standard. This means that hospitals are not specifically required to be capable of knowing every possible practitioner or entity that needs notifications or be able to meet all notification preferences (85 FR 25601). However, what it does mean, at minimum, is that hospitals must fulfill notifications for those established

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SECTION 5: GUIDANCE FOR THE COMPLIANCE ROAD AHEAD practitioners, groups, and entities that have a demonstrated need and have made that need known through notification requests for their patients while not introducing any systematic notification omissions. Specifically, to demonstrate “reasonable effort” hospitals cannot solely rely on sending e-notifications to those providers that patients identify at the point of care–many patients may not be able to name providers or know the specific name of the group or entity. To meet the requirement of sending e-notifications to those that demonstrate established care relationships and request notifications for their patients, hospitals need to use a solution that can process and respond to these e-notification requests that will be made across care settings and will come from providers across various regions and geographies. Hospitals should consider to what extent they themselves or third-party solutions can fulfill these requirements. For example, some hospital EHRs may be able to help with part of the requirements by using Direct Messaging functionality for inpatient discharges as required under Meaningful Use but may not be able to manage and respond to requests from providers that need e-notifications for treatment purposes. Hospitals should consider to what extent they themselves or other solutions can successfully address issues related to geographic reach, real-time fulfillment of e-notifications, and diversity of providers that need notifications to mitigate risk of non-compliance. What happens if hospitals do not meet the CoP e-notifications requirements? Medicare CoPs are federal regulations with which hospitals must comply in order to maintain their Medicare provider agreement. Noncompliance can lead to survey deficiencies and the risk of losing payment from the Medicare and Medicaid programs—payments which often make up close to 60% of hospital reimbursements. Deficiencies with any CoP can lead to certification termination and will set off a cascade of time-bound termination and corrective action procedures. Specifically, 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

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infection control, staffing ratios, medical records documentation, compliance with applicable federal, state, and local laws, and patient’s rights among others. The e-notifications requirements have been included within the broader Medical Record Services CoP and apply to all patients–not just Medicare patients. State survey agencies and accreditation organizations will assess compliance by auditing individual patient records, at least 10% of the average daily census and no less than 30 randomly selected patient records, where the hospital will need to show that they’ve sent e-notifications to the selected patients’ other community providers. Hospitals will also need to evidence their policies and procedures that outline the processes and systems that are in place to fulfill all e-notifications requirements. Finally, the surveyors will also conduct an interview with the executive overseeing medical records. Hospital Considerations: Hospitals across the nation are in need of solutions that will enable them to efficiently and effectively send electronic e-notifications in real time to patients’ community providers that require notification for treatment, care coordination, or quality improvement purposes. To meet compliance requirements and demonstrate that hospitals are making a “reasonable effort,” hospitals must vet solutions and assess their capabilities of meeting the outlined e-notification requirements, including notification requests from across care settings and across different geographies. Considerations should include how the hospital or its intermediary will be able to scale notification requests from providers and how the associated roster processing will be fulfilled in real time. Before relying solely on existing EHR or health information exchange solutions, hospitals need to assess their ability to meet all notification requirements and their ability to address a significant increase in e-notifications. Hospitals must seek to implement a solution that can guarantee compliance for all required e-notifications to avoid any survey deficiencies and ensure their Medicare provider agreement remains in good standing.

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SECTION 6: CMS E-NOTIFICATIONS COMPLIANCE SOLUTION

PatientPing’s Route Solution for Compliance Route: The Simplest, Most Comprehensive Solution to Achieve Electronic Patient E-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. In addition to guaranteeing CMS CoP compliance, the Route solution helps hospitals: • 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 In addition, Route provides a full audit trail of e-notification receipts. Hospitals are enabled with transparency, security and visibility into data sharing for full confidence that they are properly complying with CMS regulations. The audit trail includes: • 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

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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. LEARN MORE ABOUT ROUTE

Looking for additional insight and answers to your questions? Check out the Route frequently asked questions.

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ABOUT PATIENTPING PatientPing is an innovative care collaboration platform that reduces the cost of healthcare and improves patient outcomes by seamlessly connecting providers to coordinate patient care. The platform enables providers to collaborate on shared patients through a comprehensive suite of solutions and allows provider organizations, health plans, governments, individuals and the organizations supporting them to leverage real-time patient data to reach their shared goals of improving the efficiency of our healthcare system. For more information, please visit: patientping.com/adt-notifications

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