*Effective July 1, 2021
The CMS Interoperability and Patient Access Rule new Conditions of Participation (CoP) require mandatory notification compliance for Medicare and Medicaid participating facilities, including general hospitals, psychiatric hospitals, Critical Access hospitals and Free standing Emergency Centers, to send electronic patient event notifications of patients’ admission, discharge, and/or transfer (ADT) to their primary care provider as well as post-acute care facilities, specialists, and any other medical provider specified by the patient.
Who is Affected?
Hospitals, Psychiatric Hospitals, Critical Access Hospitals (CAHs) and Free Standing Emergency Centers (FEMs)
What is the Minimum Data?
We Require, Patient name, Treating practitioner name, Sending institution name and some optional data like: Patient diagnosis when permitted by law.
Who Gets the Data?
Patient Identified Practitioners
Primary Care Physicians (PCPs), Medical Specialists, Physician Groups, Accountable Care Organizations (ACOs), Federally Qualified Health Centers (FQHCs)
Post-Acute Providers and Suppliers
Skilled Nursing Facilities (SNFs), Home Health Care, Rehabilitation Hospitals, Long-Term Post-Acute Care (LTPAC), Hospice, and other patient identified entities.
What about Privacy and Security?
The Privacy Rule permits patient event notifications as disclosures for treatment purposes and requires the hospital to send notifications to those practitioners for whom the facility has reasonable certainty of receipt.
What about Privacy and Security?
All Medicare and Medicaid facilities must send admission, discharge, and transfer (ADT) information to all providers including out-of-network providers. These providers must have an established care relationship with the patient.
The providers can fall into the following categories:
Primary Care Physician (PCP)
Previous/New Post-Acute Care provider where patient is being referred or transferred Any physician that the patient indicates is involved in their care
Consequences of Noncompliance
All Medicare and Medicaid-certified hospitals, Critical access hospitals (CAHs) and Freestanding Emergency Rooms are required to comply with the Conditions of Participation (CoPs) for their respective programs. Noncompliance with the CoPs can result in requirements for the facilities to complete corrective action plans or, if egregious enough and left uncorrected, can ultimately result in revocation of the Medicare certification.
Proof of Notification Surveys and Risk Deficiency
Surveyors from an accreditation organization or the state will follow CMS established policies and procedures for the surveys.
Surveyors examine 10% of the average daily census or a minimum of 30+ inpatient records.
Facilities have 10 days to submit a plan of correction
Risk of CMS denial of payment, plus other sanctions
