Making sense of the proposed CMS interoperability rule update requiring electronic patient event notifications

As the largest payer in the United States, any changes proposed by the CMS that influence provider organization eligibility to receive Medicare and Medicaid payments should be observed closely. Below we explore an interesting portion of a recent proposal that, if adopted, would have a huge impact on healthcare data exchange.

Recent proposed CMS interoperability rule updates would change the Conditions of Participation (CoPs) for Medicare and Medicaid participating hospitals, psychiatric hospitals, and critical access hospitals, to require sending “electronic patient event notifications of a patient's admission, discharge, and/or transfer to another health care facility or to another community provider”.

Long story short, if you get CMS dollars, you need to be able to electronically tell someone near you when a patient is admitted. Specifically, the rule mentions HL7v2 ADT as the required method of exchange. The belief that this kind of data exchange would improve care is supported by a number of studies that show positive impacts on readmission rates and other metrics. To help understand why notification of admissions/ discharges/ transfers across a community of providers would be valuable, consider the following scenario.

A patient is admitted to an emergency department following a slip and fall at their home. With the model proposed in the CMS interoperability rule, notification of this admission and subsequent discharge would be electronically delivered to the patient’s primary care physician along with pertinent details about the encounter (time, location, attending provider, etc.). This would provide insight into the encounter and allow the PCP to immediately arrange relevant follow-ups and ensure the patient’s record is updated appropriately. Traditionally, such an encounter could go unnoticed until the patient reaches out to their PCP at which time acquiring full details about the encounter may be difficult and the optimal time to execute follow-ups may have passed.

Most EHR systems support sending the types of transactions required by the proposed CMS interoperability rule, but connecting them outside of the health system firewall has long been a challenge. Part of the reason we started Redox was to help newer cloud-based applications get these very same transactions, and our first “Data Model” was PatientAdmin – a slimmed down version of ADT. Today over 90% of Redox powered integrations leverage PatientAdmin further demonstrating the value of this kind of data exchange.

Inherent in getting the data out of the firewall is a security concern. ADT traffic typically flows only within the firewall and requires a VPN to secure across facilities. This is a clear case where networks are valuable. If three hospitals in a region needed to share data, they would each need to maintain two sides of a VPN. With a networked approach, each hospital only needs to maintain one. As the proposed CMS interoperability rule looms, IT leaders looking to meet the rule need to decide if they want to connect to an exponential number of partners or just one. As a general rule, more VPNs means more work for IT and security teams. If this proposed rule is adopted, finding a secure, scalable way to provide this functionality will be paramount.

Redox has a multitude of ways to not only help these facilities meet the requirement but also help their patients. One ADT connection to Redox can be reused across not only your local market but also for networks like Commonwell. The same connection can also be leveraged to power hundreds of digital health applications that use Redox to exchange healthcare data. With Redox’s expanding FHIR® capabilities your connection not only simplifies data exchange today but is positioned to leverage healthcare’s newest standard as it matures and achieves mass adoption.

We will continue to watch the proposed CMS interoperability rule closely and update you as things progress. In the meantime, we encourage you to think of the value this proposal would provide and to consider submitting a comment prior to the May 3rd, 2019, deadline.

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If you are interested in learning more about how Redox can help your organization execute this kind of data exchange with a single connection to our Platform, contact us today to schedule a conversation with a member of our provider organization team.