How Would Proposed CoP Requirements Impact Providers, Care Teams, & PACs?

While CMS’s proposed new Conditions of Participation (CoPs) directly impact hospitals, psychiatric hospitals, and Critical Access Hospitals (CAHs), they also have important implications on care coordination and quality improvement activities for practitioners, care teams, and PACs. We’ll review the CoP requirements and discuss their anticipated impacts below.  

Review of the Proposed E-notification CoP Requirements

CMS’s proposed e-notification CoPs would require Medicare- and Medicaid-participating hospitals, psychiatric hospitals, and CAHs to send e-notifications to eligible requesting practitioners, care teams, and PACs when their shared patients have an inpatient admission, discharge, or transfer event. To request e-notifications, practitioners, care teams, and PACs must have an established care relationship with the patient, be able to receive e-notifications, and use the information for treatment, care coordination, or quality improvement purposes.

Hospitals would be required to send e-notifications to eligible requesters at the point of a patient’s admission, discharge, or transfer. E-notifications would need to include, at minimum, patient name, treating practitioner name, sending institution name, and, if not prohibited by other applicable law, patient diagnosis.

Hospitals have the option to manage e-notification requests directly or through an intermediary. It will depend on the hospital’s selected e-notification management mechanism as to how eligible practitioners, care teams, and PACs can request and receive e-notifications.

Understanding the Impact

The proposed CoPs would allow eligible practitioners, care teams, and PACs to request e-notifications on their patients from any hospital impacted by the CoPs for purposes of treatment, care coordination, or quality improvement activities. CMS hopes to promote information sharing to encourage care coordination activities across the continuum of care and to ultimately improve patient outcomes while reducing unnecessary or duplicative care encounters.

Receiving e-notifications gives eligible practitioners, care teams, and PACs added transparency about their patients’ hospitalizations and improved insight into when the transition of care processes need to be initiated. The additional encounter information can also help streamline workflows and allow for more timely patient follow-ups. Practitioners, care teams, and PACs should consider how to effectively use and incorporate the additional information into workflows and care transition planning. For those participating in value-based care arrangements, e-notifications can further support utilization and total cost of care management efforts.