Although the electronic notification requirement within the Conditions of Participation applies to Medicaid and Medicare hospitals, it benefits all hospitals, ACOs, providers, and patients

It is 2021 and highly manual care coordination processes involving fax machines and phone calls are still being used in hospitals during transitions of care. Although automated, real-time encounter notifications (e-notifications) have long been available, some hospitals are still behind in sending e-notifications to other providers.

What is it going to take to encourage the rapid adoption of this modernized care coordination approach? While COVID-19 has certainly made providers embrace health IT to manage patient care, the Centers for Medicare and Medicaid Services (CMS) finalized their Interoperability and Patient Access Rule during the pandemic, recognizing the importance of sharing real-time data through the new e-notification requirement under the hospital Conditions of Participation. The rule forces acute care, psychiatric, and critical access hospitals to demonstrate the ability to notify patient-identified primary care providers (PCPs) and other providers whenever a patient has a hospital encounter, such as an admission, discharge, or transfer (ADT) event.

This new requirement went into effect on April 30, 2021. In this blog post, we and highlight several advantages that will come out of it, and how it will be enforced.

The Carrot: Incentives to meet CMS’ e-notification requirement

Meeting CMS’ e-notification requirement means hospitals will be in the clear from facing non-compliance penalties. Once sending e-notifications, hospitals will be equipped to reduce avoidable readmissions for patients with chronic conditions, close care gaps, and improve coordination between providers and patients.

In an Op-Ed with Fierce Healthcare, Aledade founder and CEO Dr. Farzad Mostashari, describes how e-notifications help make PCPs be aware of when their most highly vulnerable patients need them the most. The notifications prompt providers to check on patients when they are hospitalized and follow up in a timely manner when they are discharged. By initiating communication at the point of care with the population that largely faces costly chronic conditions (see chart below), providers can review medication changes and strategies to improve overall health so the patients do not end up back in the emergency room.

Dr. Mostashari has been a longtime advocate for making the exchange of ADT data mandatory. He writes, “We owe it to our communities to make sure every dollar is spent wisely. Widespread implementation of ADT alerts has the potential to save billions in unnecessary healthcare costs per year.”

The Stick: Ramifications for not complying with the e-notification requirement

Even though this new requirement is designed to improve care coordination workflows and patient outcomes, some hospitals may fail to meet the compliance deadline for the rules that went into effect on April 30, 2021. Not only may non-compliant hospitals miss valuable opportunities to improve patient outcomes this requirement intends to deliver, but they may also be at risk of losing valuable support from CMS to maintain operations.

Organizations without a compliance solution in place are scrambling to implement as soon as possible. Eventually, there will be compliance audits conducted by either a state-designated survey agency or an accredited organization that CMS appoints to oversee compliance. If the surveyors observe a hospital is not meeting compliance, hospitals could be required to provide a correction plan and demonstrate that deficiencies have been remediated. Failure to meet multiple requirements within the Conditions of Participation, including the new e-notification requirement, could result in withheld payments or the termination of a hospital’s CMS certification. More information is anticipated to come out from CMS within the next few months to further clarify the auditing process, including enforcement penalties. In the meantime, hospitals should continue to prioritize meeting compliance as quickly as possible.

The Solution: An experienced partner who provides the technical capabilities required to deliver effective encounter notifications

As Audacious Inquiry’s Chief Medical Officer, Dr. Samit Desai, described in a recent HIStalk Readers Write, hospitals should look for services that support patient-asserted and provider-attributed alerts. Audacious Inquiry provides Conditions of Participation e-notification compliance through Audacious Inquiry’s ENS® for hundreds of hospitals across the country. ENS serves more than 60 million patients nationwide and generates both patient-identified and provider-attributed notifications at the most important moments, including during transitions of care.

Learn more about how Audacious Inquiry can support your hospital’s e-notification compliance needs in the new eBook, “What Hospitals Need to Know to Comply with CMS’ Condition of Participation”. Get the answers to some commonly asked questions, including:

  • Which providers do hospitals need to notify?
  • Do hospitals need to set up connections for every single provider in their network?
  • What information needs to be included in the notifications?
  • What are the biggest gaps hospitals should prioritize?
  • Does an intermediary need to send notifications to non-participants?
  • Is “Observation Status” part of Conditions of Participation requirements?

To find out where your organization stands for e-notification compliance, take the readiness assessment.