What’s Next in E-Notifications? Harnessing the Power of Interoperability for Whole Person Care

By Molly Kane, Corporate Strategy & Policy Manager, and Chris Skowronek, Vice President, Corporate Strategy & Policy, Bamboo Health

It is hard to believe that more than a year has passed since the Centers for Medicare & Medicaid Services (CMS) Interoperability and Patient Access Rule Electronic Event Notifications (E-Notifications) Condition of Participation (CoP) went into effect.

In addition to empowering providers with real-time data and information to aid the care of their patients, provisions such as the CMS E-Notifications CoP have helped to improve interoperability across the care continuum.

The one-year mark provides a great opportunity to break down the implications of the rule, reflect on the importance of e-notifications, and think ahead to the future of healthcare and the delivery of interoperable, whole person care. This close assessment of the key CoP compliance considerations can help hospital executives, chief information officers, and compliance professionals determine their options and make more informed decisions for their organizations moving forward.

CMS E-Notifications Review and Interpretative Guidance Takeaways

Designed to help hospitals better serve their patients through improved care coordination and enhanced interoperability among providers, the E-Notifications CoP that CMS finalized as part of the Interoperability and Patient Access Rule requires hospitals, psychiatric hospitals, and critical access hospitals to share electronic admission, discharge, and transfer (ADT)-based event notifications with other community-based providers and care team members including post-acute care facilities.  

Hospitals utilizing an electronic health record (EHR) service provider or other electronic administrative system that is conformant with the content exchange standard HL7 v2.5.1, must make a reasonable effort to send real-time electronic notifications:  

• At the point of inpatient and observation admission, discharge, and transfer, and at emergency department (ED) presentation and discharge  
• To the patient’s established primary care provider (PCP), established primary care practice group or entity, other practitioners, practice groups or 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, the patient’s name, treating practitioner’s name, and sending institution’s name 

CMS’s Interpretive Guidance for the ADT E-Notifications CoP for hospitals, which followed shortly after the initial deadline, sheds further light on the rule and what it means for the future of care coordination. Of note, the Interpretive Guidance strengthened its previous language around hospitals needing to make a “reasonable effort” to send e-notifications, to hospitals needing to make “every attempt” to send these notifications. Based on this, hospitals need to ensure that they are making every attempt to successfully send notifications to applicable providers and entities that need the information for treatment, care coordination, or quality improvement activities – indicating a push toward real-time data sharing as an essential component to the successful care coordination of patients.

CMS additionally reiterated that nothing in the CoP restricts a hospital’s ability to share information in accordance with its current data sharing policies to anyone else who is permitted legally to receive that information. In line with this, CMS specifically called out the permissibility of including notifications to an ACO via an ACO attribution list. Based on this, CMS has made it clear that they understand that certain organizations use attribution lists, and that hospitals are permitted to share with these organizations based on these lists. The expressing naming of ACO attribution lists within the Interpretive Guidance is indicative of CMS’s recognition that real-time, actionable information is necessary for care coordination across multiple settings and use cases, and that additional provider types must be included within healthcare interoperability going forward. 

As a result, future e-notifications requirements could explicitly include the use of attribution lists. This trend will likely continue as the need to share information with an increasing number and type of entities and providers will only expand over time. Hospitals and health systems need to make sure that their organizations are not only complying with the CoP as it stands today, but are prepared for potential new scenarios as the interoperability landscape evolves.

What’s Next for E-Notifications and Real-Time Healthcare Data?

Looking ahead, the question becomes: what’s next for e-notifications and other forms of real-time healthcare data? The CMS CoP and its accompanying Interpretative Guidance signal a range of implications for the future of e-notifications and how compliance requirements may evolve. By requiring hospitals to send real-time e-notifications at the point of inpatient ADT, and at ED presentations or discharges, CMS has clearly recognized that timely, actionable information on patients is a critical component for interoperable healthcare. This real-time information about patients’ care encounters across providers and settings has, and will continue to, introduce new levels of visibility for respective care teams, to drive:

• Reduction of unnecessary ED utilization
• Prevention of avoidable hospital readmissions
• Avoidance of duplicative procedures and tests
• Avoidance of prescription contradictions
• Holistic management of behavioral health conditions 
• Identification and management of social determinants of health  

The result is an advancement toward the growth of value-based care delivery models and increased interoperability across the healthcare ecosystem, with each of the two further driving the other. In the future, we can expect this trend to continue and set the stage for future changes to value-based care programs and other rulemaking. 

Harnessing the Power of Interoperability for Whole Person Care

Rules such as the CMS CoP have established a foundational level of interoperability; from which the seeds of change will continue to take shape nationwide. Just ten years ago, the concept of clinical data being passed from one healthcare organization to the next was nearly unheard of. It was a world in which providers are their respective organizations existed in silos, unable to effectively coordinate with the other members of a patient’s care team in a timely, seamless manner.  

Today, healthcare is more connected than ever, with billions of transactions underlying the exchange of data across settings and providers. In addition to the CMS CoP, there have been numerous recent changes to the interoperability and value-based care landscape, with directional changes in the industry favoring a focus on care coordination, from organizations such as the Office of the National Coordinator for Health Information Technology (ONC) and the Center for Medicare & Medicaid Innovation (CMMI). The current administration has similarly prioritized healthcare innovation – spearheading efforts to transform the healthcare landscape to include a deeper focus on health equity and enable the continued movement toward value-based care across the physical and behavioral health spectrums. 

While the CMS e-notifications CoP has helped expand the use of e-notifications, it is by no means the final solution. We are at a unique inflection point where the emphasis must move beyond simply sharing real-time information toward making data meaningful and actionable to ensure that all healthcare providers, payers, and ultimately, patients benefit from its use. Through actionable interoperability, we can minimize the time that providers and care managers spend managing and sifting through data, and instead make healthcare information enable them in effective ways where they can focus their efforts on patient care. 

Data should be a tool to ease a provider’s job, rather than increase administrative burden. When providers have access to meaningful, timely healthcare data integrated into their existing clinical workflows, both providers and their patients will feel the positive impact of healthcare interoperability and its ability to enable whole person care. 

Author Bios

Molly Kane is the Corporate Strategy & Policy Manager for Bamboo Health. Prior to her time at Bamboo Health, Kane worked in payer policy at athenahealth, where she led the regulatory review of CMS proposed and final rules and coordinated athena’s operational response to payer and industry changes. Molly holds a degree in government and legal studies from Bowdoin College.

Chris Skowronek is a healthcare industry operations and strategy leader, with a track record of success managing and driving product development, healthcare optimization, and innovation. He is Bamboo Health’s Vice President of Corporate Strategy & Policy, and he has held previous healthcare executive positions responsible for value capture, P&L, and program implementations with a specialization in population health management, healthcare analytics, workflow optimization, and network integration. Chris is skilled in strategic planning, provider value capture, healthcare analytics, provider engagement and relations, and healthcare policy. He received his master’s degree in Healthcare Administration from the University of North Carolina at Chapel Hill.