CMS Releases Guidance for Hospitals Implementing Interoperability Rule

The Centers for Medicare & Medicaid Services (CMS) released interpretive guidance on hospital admission, discharge, and transfer notification requirements outlined in its May 2020 final rule on interoperability and patient access, which includes Medicare conditions of participation (CoPs) for hospitals, psychiatric hospitals and critical access hospitals. The new CoPs are included in the medical records requirements at 42 CFR 482.24(d)(1-5) for hospital; and will help improve care coordination “by allowing a receiving provider, facility or practitioner to reach out the patient and deliver appropriate follow-up are in a timely manner.” Due to the COVID-19 public health emergency, CMS gave hospitals until May 1, 2021, to implement these requirements.

Conditions of participation for hospitals that have an electronic medical records system (EHR) and the system conforms to the content exchange standard HL7 2.5.1 at 45 CFR 170.205(d)(2). Standards include:  

  • Use in accordance with state and federal statues to the hospital’s exchange of patient health information (PHI);
  • Facilitate notification of patient admission, discharge and transfer information from hospital’s emergency department or inpatient services when applicable; and
  • Provide patient name, practitioner name, facility name during exchange (if patient allows via expressed privacy preferences).

To review the memorandum summary, click here.