Fast Facts for Hospitals: CMS’s Final Interoperability and Patient Access Rule

This fact sheet outlines the hospital e-notifications Condition of Participation (CoP) requirements that CMS has finalized as part of its Interoperability and Patient Access Final Rule (85 FR 25510).

  • Who is impacted by CMS’s new e-notifications Condition of Participation?
    • Medicare- and Medicaid-participating hospitals, psychiatric hospitals, and Critical Access Hospitals (CAHs) with EHR systems or other electronic administrative systems that are conformant with the HL7 2.5.1 content exchange standard.
  • What are the requirements?
    • Impacted hospitals will be required to send electronic event notifications, or e-notifications, at the time of a patient’s inpatient admission, discharge, and transfer, as well as at the time of Emergency Department (ED) presentation and discharge.
    • E-notifications must contain, at a minimum, patient name, treating practitioner name, and sending institution name as well as the event or encounter detail.
    • Each hospital has to demonstrate that is has made a reasonable effort to send notifications to all applicable and established primary care practitioners, practice groups, post-acute care providers, or other identified entities which need to receive updates on the patient’s status for purposes of treatment, care coordination, or quality improvement.
    • Hospitals will need to send e-notifications at the time of a patient’s ED visit and at the time of a patient’s inpatient admission, discharge, and transfer.
    • Hospitals must have a system in place that uses the HL7 2.5.1 standard for e-notifications. Hospitals may, however, also use other standards to support their notification systems.
  • How can impacted hospitals meet compliance requirements?
    • Hospitals have the option to manage and exchange e-notification requests directly or by using an intermediary.
  • When will the new CoP requirements go into effect?
    • The CoP requirements will apply May 1, 2021.