The CMS Interoperability and Patient Access final ruling, including the changes to the Conditions of Participation, has created unique challenges for healthcare providers across the care continuum. Hospitals and ambulatory providers have concerns about the potential pitfalls that these new rules may cause—particularly for downstream providers.
1. Changes to Ambulatory Workflows
Alert fatigue is an already pressing concern for ambulatory providers, and the new interoperability rule will add a substantial amount of new data received by providers without clear ways of managing it.
To help mitigate frustration, burnout, and unnecessary administrative burden, hospitals can take ambulatory workflow into account when choosing an intermediary to fulfill CMS requirements. One example includes implementing a solution that works with provider preferences for notifications—such as an institutional direct messaging inbox or a provider-specific inbox.
Additionally, sending notifications when and where appropriate can help decrease the likelihood of them being ignored. Making notifications easily accessible by providers can also help facilitate better collaboration between hospitals, primary care, and post-acute providers.
2. Avoiding Financial Penalties
The interoperability and transfer of information is required as a Condition of Participation, which means organizations that are found not in compliance can be penalized. Yet unclear verbiage has contributed to hospital administration fears around incurring financial penalties.
Hospitals must make a “reasonable effort” to ensure notifications are sent to the appropriate downstream providers, but it’s not clear what constitutes a “reasonable effort”. For now, when evaluating intermediaries, hospitals should clarify the intermediary’s ability to prove “reasonable efforts” by ensuring the solution not only sends notifications, but has the reporting to show and track these efforts.
3. Understanding What EMRs Need for Compliance
Currently, existing singular electronic medical record (EMR) systems may not fully meet the requirements of the Conditions of Participation. Reasons for partial compliance include:
- Missing attribution files
- Only offering access to ADT data
- No functionality for sharing with downstream providers
- Lack of persistent records
- Lack of integration into provider workflow
To avoid using multiple intermediaries to meet requirements, finding a singular solution, like that offered by Collective Medical, ensures full compliance and can reduce cost and administrative burden while enabling a smoother implementation process.