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What the CMS- and ONC-proposed Interoperability Rules Mean for Hospitals

Continuing the journey toward interoperable health information

What the CMS- and ONC-proposed Interoperability Rules Mean for Hospitals

To promote data sharing, CMS and ONC jointly released two proposed rules on March 4, 2019. Their goal is to ensure that every American can, without special effort or advanced technical skills, see, obtain, and use all electronically available information that is relevant to his or her health and care. The rules cover data sharing to advance care continuity, patient access to information, and prevention of information blocking. Most of the recommendations in the rules for hospitals were proposed for comment, without a specific timeline for implementation.

Which providers and hospitals are impacted by these rules?
The CMS rule applies to Medicare- and Medicaid-participating short-term acute care hospitals, long-term care hospitals, rehabilitation hospitals, psychiatric hospitals, children’s hospitals, cancer hospitals, and critical access hospitals (CAHs).

The ONC rule applies more generally to healthcare providers that are participating in CMS funded health IT programs, such as Promoting Interoperability, as well as to a broader definition of providers listed in the Public Health Service Act.

What are hospitals required to do under these proposed rules?
The CMS-proposed rule requires covered hospitals and providers to enhance their use of interoperability beyond what they are already doing under the CMS Promoting Interoperability Program. For hospitals, CMS has proposed a number of new requirements that will continue to advance an interoperable health IT system.
• The most significant proposal would modify the Conditions of Participation for hospitals, CAHs, and other hospital classifications to require them to send electronic patient event notifications upon a patient’s transition to another provider or care setting. The notification would include the patient’s basic personal information as well as diagnosis, to the extent not prohibited by other applicable law. There is no specific timeline associated with this proposed rule.
• CMS proposed two means of discouraging health care providers and hospitals from engaging in the practice of information blocking. One requires the public naming of clinicians, through an indicator on the Physician Compare website, who fail to attest as part of the CMS Promoting Interoperability Program. The other involves penalties. More information on the Information Blocking provisions are contained in the ONC proposed rule.
• To promote better Provider Directory information, CMS has proposed a requirement that all providers update their electronic digital contact information (i.e. Direct Address) in the National Plan and Provider Enumeration System (NPPES).
• Providers will be required to communicate any changed information to the NPPES within 30 days of the change.
• CMS will publicly report the names and NPIs of those providers who do not have digital contact information included in the NPPES system by the second half of 2020.
• The CMS-proposed rule also includes a request for information regarding data sharing with post-acute care hospitals and other service providers not covered under the Promoting Interoperability Program.

What standards need to be supported under this rule?
It is important to note that as with past rules, CMS defines what the impacted entity needs to do, and ONC defines how to do it through technology requirements. As part of the ONC-proposed rule, a number of standards were outlined in support of the CMS proposals.
• FHIR DSTU 2
• United States Core Data for Interoperability (USCDI)
• HL7 2.5 for ADT Alerting

InterSystems, a Leader in FHIR and Interoperability, Can Help You Comply with the CMS Interoperability Rule

Customers use our solutions to bring together patient and member data from EMRs, insurance claim systems, and other sources across the healthcare ecosystem.

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Beyond Promoting Interoperability

Moving to the next phase of interoperability is a strategic imperative that hospitals need to embrace if they want
to maintain a leading edge. It will give providers across the care continuum access to the information they need
for better care coordination and delivery, at a lower cost. And that is at the heart of the CMS-proposed rule.

No data management vendor has a greater commitment to healthcare or more relevant experience than InterSystems. Globally, more than a billion health records are managed by solutions built on our technology. The most sophisticated private and government providers depend upon devices, records, and IT powered by InterSystems.