CMS’s Interoperability and Patient Access Rule: What to Know and How to Comply, with Dr. John Glaser

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Jul 1, 2020, 8:26 PM

With CMS’s Interoperability and Patient Access rule recently finalized, PatientPing sat down with Dr. John Glaser, former CIO & CEO, to discuss his thoughts and feedback on the rule and the impact it will have on providers. Dr. Glaser shares how efforts from ONC and CMS to promote interoperability will shape the way providers deliver patient care, what hospitals, post-acutes and community providers need to know about the rule, and how they can best succeed and comply.

Dr. John Glaser

How do you think efforts from the ONC and CMS to promote interoperability and eliminating information blocking will impact healthcare providers and the care that patients receive?

I believe it will open new opportunities for providers across the care continuum to collaborate and this will ultimately benefit patients and improve the care they receive. However, I expect providers will be concerned about the addi

tional resource burden required to enable interoperability efforts. These concerns should be addressed and mitigated by accessible and easy to implement technology solutions and I believe the market will address that need.

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.

Another opportunity of added information sharing is an improved understanding of  patient context for the clinician at the point of care. Providing clinicians and care team members with more information and patient context not only improves clinical decision making and efficiency but allows for more attention to be focused on the patient. 

A third opportunity presents itself as the industry transitions from a fee-for-service system towards value-based care where increased care collaboration is critical to positively impact care outcomes and the total cost of care management. When providers have better access to their patient’s information across the continuum, they are more likely and willing to enter value-based care arrangements. Sharing information will contribute to reducing  unnecessary over-utilization and waste in the system, which is estimated to be between $760 billion to $935 billion annually, according to The Journal of the American Medical Association.

The Interoperability and Patient Access rule includes a CMS e-notifications Conditions of Participation requirement. What is important to know about this requirement?

As the rule is written, hospitals, psychiatric hospitals and Critical Access Hospitals must send electronic notifications in the form of ADT messages to patients’ other providers for admission, discharge, and transfer events as well as ED visits. Hospitals are required to share e-notifications with practitioners, practice groups or entities, and post-acute care providers that have an established care relationship with the patient and that need the information for treatment, care coordination, and quality improvement purposes. 

For more information about the e-notifications CoP please visit

How are hospitals impacted by the rule and how can they succeed? 

Hospitals need the ability to manage and respond to all of these different notification requirements and notification requests from patients’ established providers. This can quickly become overwhelming and hospitals should work to minimize administrative and technical burdens associated with being in compliance.

It’s crucial to note that the population of providers potentially needing and requesting notifications  from hospitals is not just limited to their city, state, or region, but reaches across the entire country. Thus, it’s important to consider primary referral and immediate community partners as well as those that may be located in different geographic regions.

For example, if patients who live across state lines or “snow bird” patients make up a sizable percent of a hospital’s patient volume, it’s likely that eligible practitioners or referral partners from those areas will also request e-notifications. It’s unlikely that state based HIEs can fulfill requests from facilities outside their service region.

CMS gives impacted hospitals the option to meet e-notifications requirements through an intermediary or by directly managing e-notifications. Hospitals should assess the types of technical solutions that can best fulfill the variety, volume, and scope of e-notification requests while also meeting security requirements.

Look, at the end of the day there are many requirements included in both the CMS and ONC rules with patie

nt-directed interoperability, FHIR API requirements, information blocking to name a few. If you are a CIO, you likely have your hands full, so assessing what work can or should be outsourced to vendors that can meet the prescribed requirements is critical so that you can focus on other strategic initiatives.

Here is a quick compliance checklist to help guide you.

What impact does the rule have on other community-based physicians and post-acutes and how can they succeed?

That’s a great question and it notes that we must take a look at the entire continuum of care. Practitioners, practice groups and entities, and , post-acutes have the ability to receive information whenever one of their patients is admitted, discharged or transferred from any impacted hospital.

As such, post-acute providers, for example, skilled nursing facilities and home health agencies, as well as practitioners and entities affiliated with a patient’s primary care practitioner  should identify those hospitals that are referral partners and those that see their patients so the notification requests can be directed comprehensively. As you can imagine, patients often seek care outside of their immediate geographic region, so having the ability to request notifications from any impacted hospital is incredibly helpful for care coordination purposes. 

Practitioners and post-acutes should also consider how e-notifications can be used effectively across their organization. Because e-notifications support care coordination activities, organizations should consider change management needs to help optimize the impact of e-notifications. 

So if you are a physician group with risk contracts or a community provider trying to coordinate care for your patients, there is a lot of value in this rule for you.

What kinds of technology solutions can providers adopt to help their organization comply under the new rules?

Providers have several technology options, so it’s important for them to find and select the solution that can best meet their needs. 

In particular for hospitals that are considering ways to share e-notifications, it’ll be important to select solutions that meet the highest security standards to protect patient data and privacy, have a credible track record performing patient matching and information routing, and can reliably meet regulatory requirements. 

Hospitals should consider the types and geographic location of referral partners and make sure that any selected technology solution can support the full scope of notification requests from these provider types. Some solutions may be limited in their geographic reach or notification scope, so hospitals should consider how solutions can meet the full set of requirements. 

Practitioners, practice groups,, post-acutes, and other entities who want to receive more information and notifications on their patients should consider solutions that have a flexible approach to make patient updates and provide options for how and what types of notifications are received.  Providers should look for solutions that best fit their workflows and that have the ability to integrate into their EHR or care management system.

Ultimately, recognizing that patients travel to nearby states and sometimes across the country to seek care, providers should take into account the geographical coverage of the e-notification solution they choose.

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