eNotifications: Meeting the CMS Final Rule

By Justin Sims

Just as the COVID-19 pandemic was starting to take hold, CMS published the Interoperability and Patient Access Final Rule.  The regulation requires hospitals to send admission and discharge notifications (eNotifications) to a patient’s PCP and other post-acute care providers.  

It is clear this is important to CMS.  They chose to add this regulation as a “Condition of Participation” (CoP) in Medicare -- something that they very rarely change.  

About one month later, due to both the scale of the Final Rule changes and the pandemic, CMS gave hospitals some breathing room by delaying the implementation of the rule until May 1, 2021.

Before I get into “how” hospitals can satisfy this rule let's think about “why” CMS see this as so important.

The fact that they have made this a CoP gives us the biggest hint -- the CoP is all about patient safety and CMS believes it is in the best interests of each patient for their primary care provider to know what happened in the walls of the hospital.  Reducing hospital readmissions and eliminating waste seem secondary -- they want the PCP, or other post-acute care provider, to take responsibility for the patient’s health and they can’t take responsibility if they don’t have information about hospital encounters.

This takes us to the “how”.  Here at careMESH, we put together an Advisory Note that lays out 3 strategies for a hospital: A) they can build their own systems and processes, B) work with their local HIE, or C) rely on a third-party provider to do the work.  I’m not going to repeat the contents of the paper here but I am going to make the overarching point that hospitals should NOT implement a solution in isolation of their other strategies for engaging in a robust manner with community providers.  

If you are a hospital and want to know how to meet the CoP as part of a wider strategy of engaging with community providers, please download the Advisory Note and Contact Us anytime.

Justin