In March 2020, the Centers for Medicare & Medicaid Services finalized the Interoperability and Patient Access final rule, which includes a section that modifies the Medicare Conditions of Participation that introduces patient event notifications.
To comply with the patient event notification CoP, hospitals with an electronic health record are required to send electronic patient event notifications for patient admissions, discharges and transfers to post-acute providers, primary care providers, physicians, suppliers or other practitioners primarily responsible for the patient’s care – such as a dialysis facility or oncologist.
The updated CoP goes into effect May 1, 2021, and hospitals that are not in compliance risk losing future Medicare funding.
“To reduce the burden of fulfilling CMS’s requirements, the CoP explicitly recognizes the ability of a third party, or intermediary, to facilitate the sending of patient event notifications on behalf of hospitals,” said Dr. Jordan Tannenbaum, vice president, CIO and CMIO at Saint Peter’s Healthcare System, based in New Brunswick, New Jersey.
“To comply with CMS’s patient event notification CoP, Saint Peter’s University Hospital needed a third-party solution to notify all required recipients about patient admissions, discharges and transfers, in accordance with the CoP.”
The provider organization turned to vendor CarePort, which helps Saint Peter’s University Hospital comply with CMS’s patient event notification CoP through its newest offering, CarePort Interop.
CarePort offers a national network of providers and established workflows for sharing ADT information in real time. CarePort Interop is designed to be a one-stop shop solution that supports compliance by the May 1, 2021, deadline.
“The hard results will be notifying all required stakeholders – whether post-acute providers, primary care providers, physicians or suppliers – of patient admissions, discharge or transfers.”
Dr. Jordan Tannenbaum, Saint Peter’s Healthcare System
“To comply with CMS’s patient event notification requirements, Saint Peter’s University Hospital must be able to reach all providers mandated within the CoP – including both in-network and out-of-network providers – and CarePort enables Saint Peter’s to do so,” Tannenbaum said.
“Hospitals that rely on their EHR or health information exchange may not achieve full compliance with CMS’s notification requirement.”
CarePort Interop provides a simple set-up process and no onboarding requirements for post-acute providers – ensuring the infrastructure is in place before the CMS deadline, he added.
“The solution is EHR-agnostic, and will integrate into the hospital’s existing workflows, as well as into the hospital’s EHR – which is from Paragon,” he explained. “Saint Peter’s can reduce the operational costs of complying with the new CoP while simultaneously achieving streamlined care coordination.”
MEETING THE CHALLENGE
CarePort Interop is embedded within Saint Peter’s University Hospital’s EHR and workflows. It will be used by hospital employees who are directly responsible for or involved in a patient’s admission, discharge or transfer – including discharge planners, case managers, or anyone in a care coordination or population health role.
“Saint Peter’s will be able to identify and notify a patient’s established care providers across CarePort’s national network of more than 900,000 physicians and more than 110,000 post-acute providers,” Tannenbaum said.
CarePort Interop was designed to fit into existing workflows, which makes implementation more seamless, and will allow for immediate compliance when CMS’s rule officially goes into effect next month, he added.
The solution has not been deployed yet, only implemented in advance of the May deadline.
“The hard results will be notifying all required stakeholders – whether post-acute providers, primary care providers, physicians or suppliers – of patient admissions, discharge or transfers,” Tannenbaum said.
“Hospitals must make a ‘reasonable effort’ to notify all applicable post-acute care services providers and suppliers, as well as the individual primarily responsible for that patient’s care – whether the patient’s established primary care provider, the patient’s established primary care practice group, or other practitioners responsible for the patient’s care – and the technology will help Saint Peter’s fulfill this requirement,” he said.
ADVICE FOR OTHERS
“Other hospital organizations should do their due diligence to ensure they have a solution in place prior to the May 1, 2021, deadline, that can ensure compliance under CMS’s patient event notification CoP,” Tannenbaum advised.
“There are some misconceptions regarding the CoP and what is required to achieve compliance,” he added. “For example, hospitals may wonder whether the EHR, or participation in an HIE, fulfills the CoP requirements. However, reaching post-acute providers is actually a significant gap for EHRs and can prevent organizations from achieving compliance for this particular requirement, while HIEs cannot ensure compliance if they can only reach providers that subscribe to their alerting service.”