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

Ahead of CMS’s Proposed Interoperability and Patient Access Rule being launched, PatientPing sat down with Dr. John Glaser, Senior Vice President, Population Health at Cerner, to discuss his thoughts and feedback. 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 providers need to know about the proposed rule, and how they can best prepare to succeed once the rule is finalized.

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 additional 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 proposed CMS e-notification Conditions of Participation requirement. What is important to know about this requirement?

As the proposed rule is written, hospitals, psychiatric hospitals and Critical Access Hospitals must send electronic notifications in the form of ADT messages to requesting parties when a patient is admitted, discharged, or transferred. Hospitals would need to share complete e-notifications with eligible requesting practitioners, care team members, and post-acute providers that have an established care relationship with the patient.

What do you think will be the impact on hospitals and how should they prepare?

Hospitals will need the ability to manage and respond to all those different requests. It could quickly become overwhelming and they must prepare to minimize administrative and technical burdens associated with being in compliance.

It’s crucial to note that the population of those potentially making requests is not just within their city, state, or region, but 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 requests through an intermediary or by directly managing e-notifications. Hospitals should assess what type of technical solution will be necessary to 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 patient-directed interoperability, FHIR API requirements, information blocking to name a few. If you are a CIO, you will likely have your hands full, so assessing what work can or should be outsourced to vendors that can meet the prescribed requirements will be important so you can focus on other strategic initiatives.

What will the impact be for other community-based physicians and post-acutes and how should they prepare?

That’s a great question and it notes that we must take a look at the entire continuum of care. Physicians, post-acutes and patients’ care teams will 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 physicians and care teams 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 notification from any impacted hospital will be incredibly helpful for care coordination purposes.

Physicians and post-acutes should also consider how e-notifications will be used effectively across their organization. These workflow and staffing considerations can help as planning for e-notification gets underway. 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 do you think will be necessary for providers to consider and adopt?

Providers will have several technology options and it’ll be 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.

Physicians, care teams, post-acutes, and other practitioners 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.