The CMS E-Notifications CoP Compliance Checklist

The new CMS Condition of Participation requires hospitals to share e-notifications.

CMS’s announcement on March 9th of new Admit, Discharge, and Transfer Electronic Notifications Conditions of Participation has left many wondering, what does this mean for hospitals? What needs to be done in order to become compliant by May 1, 2021?  Below is a quick summary of the rule and a compliance checklist to help answer those questions.

New CMS Conditions of Participation require all hospitals, psychiatric hospitals, and Critical Access Hospitals utilizing an electronic medical records system or other electronic administrative system which is conformant with the content exchange standard HL7 v2.5.1 to make a reasonable effort to send real time electronic notifications:

At: the point of inpatient and observation admission, discharge, transfer and at emergency department presentation or discharge.

To: Every patient’s established PCP, established primary care practice group or entity, other practitioners/practice groups/entities identified by the patient as primarily responsible for his or her care, and applicable post-acute providers who need to receive notification for treatment, care coordination, or quality improvement purposes.

Containing: at minimum patient name, treating practitioner name, and sending institution name.

Compliance Checklist

What data need to be shared?

Send real-time e-notifications containing patient name, treating practitioner name, and sending institution name at the point of patient admission, discharge, and transfer for ED, inpatient, and observation patients

  • Following data elements encouraged but not required: chief complaint, medication profile, discharge disposition, and diagnoses

To whom do you need to send data?

Send e-notifications to patient-identified practitioners

  • Established primary care practitioners
  • Other practitioners primarily responsible for a patient’s care
  • Named treating providers with signed patient consent for patients in psychiatric units

Have the ability to meet e-notification requirements for all recipients who need to receive notifications for purposes of treatment, care coordination, and quality improvement

  • Entities affiliated with a patient’s primary care practitioner including:
    • Primary Care Practices
    • Accountable Care Organizations
    • Federally Qualified Health Centers
    • Physician Organizations
    • Independent Physician Association
    •  Multi-specialty Practice
  • Post-acute services providers and suppliers with whom the patient has an established care relationship prior to admission or to whom the patient is being transferred or referred including:
    • Skilled Nursing Facilities
    • Home Health Agencies
    • Hospices
    • Inpatient Rehab Facilities
    • Long-term Acute Care Hospitals

This compliance checklist has been produced by PatientPing, Inc. for educational purposes only.