• Skip to main content
  • Skip to header right navigation
  • Skip to site footer
  • (888) PHC-INC1

HBS logo family- Patton

Patton Healthcare Consulting

  • Products & Services
    • Survey Prep & Support
      • Survey Readiness
      • Survey Preparation
      • CMS Compliance Support
      • Patient Safety System Support
      • Remote Survey Technology
    • Adverse Decision Response & Recovery
    • Disease-Specific Care Support
      • Stroke Certification Assistance
      • Orthopedic Certification Assistance
    • Continuous Advisory Services (CAS)
    • Interim Healthcare Leaders
    • Tracer Team Boot Camp
    • Healthcare Building Solutions
    • Optimizing Hospital Operations
  • About Us
    • About Patton
    • Certifications We Support
    • Our Parent Company
    • Our Team
    • Patton Professionals
    • Testimonials
    • Patton FAQs
  • Resources
    • Patton Post Newsletter
    • Patton Blog
    • Additional References
  • Client Login (CAS)
  • Careers
  • CONTACT
Sending Notice To Other Providers

Sending Notice To Other Providers

You are here: Home / Q&A / Sending Notice To Other Providers
September 30, 2021

Question:

We originally attempted to comply system-wide with CMS regulation CMS 432.13(b)(4) Right of Notice of Admission by building the question into the nursing admission assessment, with the intent that when the patient said yes to family, provider, or other notifications, that would trigger a task downstream for those notifications.  

Now, to comply with 42 CFR 482.24(d)(1-5) for hospitals and 42 CFR 485.638(d)(1-5) for CAHs, our HIM and IS teams have set automatic notifications via ADT processes, assuming that the patient’s consent is covered in our general consent language.  

In reading the QSO memo from May 7, 2021, *QSO-21-18-Hospitals/CAHs (cms.gov) which is an advance copy of interpretative guidance for hospitals, including CAH and psych hospital, it appears if I am reading this correctly, that the patient must still consent to having their records sent.  

We want to get your input as likely we need to discontinue the nursing admission question as it is moot in sequence and ensure expressed consent by the patient at the point of admission registration.    Any insights or advisements you can provide would be very helpful.

Answer:

The new QSO (QSO 21-18) memo makes it clear that hospitals have to send notice to other providers for emergency room visits and admissions, external transfers, and discharges if that notice is not “inconsistent with the patients expressed privacy preferences.”  

This new wording is different than the first draft which sounded more like you had to get “consent” from the patient to send the notices.  We have not seen this comfortably implemented yet, but you could consider adding this new communication to either your general consent or some special consent policy.  You can notify the patient of the new communications but give the patient an “opt out” option.  The default would be to communicate (say what?!).  

This is summarized a bit more below:

QSO memo 21-18 for hospitals and critical access hospitals (effective June 30, 2021) requires hospitals to send notice to other providers for emergency room visits and admissions, external transfers, and discharges.  

The three A-tag requirements are discussed below:

  1. A-0470:  Requires notice be sent for registration as an inpatient or emergency room patient to external providers.   CMS points out that this may require two notices, one stating that the patient has registered for treatment in the ED, and a second notice stating the patient has been admitted to the hospital.  CMS also makes it clear in their guidance that emergency room notice must be sent regardless of the decision to admit or not.  For acute care hospital patients this notice needs to be sent if the notice is “not inconsistent with the patients expressed privacy preferences.”   We have heard hospitals discuss a change to the general consent that notifies them of the plan to communicate to their PCP and gives them an “opt out” option.  If they don’t opt out, then all of the required notices are sent for acute care patients.  Different rules apply for BH patients.
  2. A-0471:  Requires notice be sent to post-acute providers when a patient is discharged from the hospital. So, if your patient has a PCP and a cardiologist or other specialist the patient identifies as primarily responsible for their care, you would want to ensure that both providers receive the aftercare notice.
  3. A-1673:  Contains the same registration in the ED or as an inpatient notice be sent but the guidance specifically refers to psychiatric hospitals; a specific consent must be obtained from the patient to send the notice to other providers.  In this case, a specific consent must be obtained from the patient to send the notice to other providers. This contrasts with the general hospital guidance which included obtuse language stating the notice sent should “not be inconsistent with the patients expressed privacy preferences.”
Sending Notice To Other Providers
Category: Q&A
Previous Post:Wire Shelving Shelf Liners
Next Post:Timing of Pre-Induction Assessments

Reader Interactions

Leave a Reply Cancel reply

Your email address will not be published. Required fields are marked *

Sidebar

Enter your email address to follow this blog and receive notifications of new posts by email.

Loading

Archives

Categories

  • Company Announcements
  • COVID-19
  • Preliminary Denial of Accreditation
  • Q&A
  • Survey Readiness

Recent Posts

  • CMS Strengthens Oversight of Accrediting Organizations: What It Means for Your Accreditation Strategy
  • Losing Deemed Status: What the Revised CMS QSO-18-12 Memo Means for Your Hospital
  • Serious Reportable Events – Physical Environmental Compliance
  • Navigating Hospital CPR Requirements
  • Maintaining Eye Wash Station Compliance

Archives

  • June 2026
  • April 2026
  • March 2026
  • January 2026
  • December 2025
  • November 2025
  • October 2025
  • September 2025
  • July 2025
  • May 2025
  • March 2025
  • February 2025
  • January 2025
  • December 2024
  • November 2024
  • September 2024
  • June 2024
  • April 2024
  • March 2024
  • February 2024
  • August 2023
  • June 2023
  • May 2023
  • February 2023
  • January 2023
  • November 2022
  • October 2022
  • September 2022
  • August 2022
  • July 2022
  • June 2022
  • May 2022
  • April 2022
  • March 2022
  • February 2022
  • January 2022
  • December 2021
  • November 2021
  • October 2021
  • September 2021
  • June 2021
  • May 2021
  • April 2021
  • March 2021
  • February 2021
  • January 2021
  • December 2020
  • November 2020
  • October 2020
  • September 2020
  • August 2020
  • July 2020
  • June 2020
  • May 2020
  • March 2020
  • February 2020
  • January 2020
  • November 2019
  • September 2019
  • August 2019
  • July 2019
  • June 2019
  • May 2019
  • April 2019
  • March 2019
  • January 2019
  • November 2018
  • October 2018
  • September 2018
  • August 2018
  • July 2018
  • April 2018
  • March 2018
  • February 2018
  • December 2017
  • November 2017
  • October 2017
  • June 2017
  • April 2017
  • March 2017

Categories

  • Company Announcements
  • COVID-19
  • Preliminary Denial of Accreditation
  • Q&A
  • Survey Readiness

Meta

  • Log in
  • Entries feed
  • Comments feed
  • WordPress.org

© 2021 – 2026 Patton Healthcare Consulting, an HBS Company.  All Rights Reserved

Privacy Policy | Cookie Policy

Manage Cookie Consent
We use cookies to optimize our website and our service.
Functional Always active
The technical storage or access is strictly necessary for the legitimate purpose of enabling the use of a specific service explicitly requested by the subscriber or user, or for the sole purpose of carrying out the transmission of a communication over an electronic communications network.
Preferences
The technical storage or access is necessary for the legitimate purpose of storing preferences that are not requested by the subscriber or user.
Statistics
The technical storage or access that is used exclusively for statistical purposes. The technical storage or access that is used exclusively for anonymous statistical purposes. Without a subpoena, voluntary compliance on the part of your Internet Service Provider, or additional records from a third party, information stored or retrieved for this purpose alone cannot usually be used to identify you.
Marketing
The technical storage or access is required to create user profiles to send advertising, or to track the user on a website or across several websites for similar marketing purposes.
  • Manage options
  • Manage services
  • Manage {vendor_count} vendors
  • Read more about these purposes
View preferences
  • {title}
  • {title}
  • {title}
Manage Cookie Consent
We use cookies to optimize our website and our service.
Functional Always active
The technical storage or access is strictly necessary for the legitimate purpose of enabling the use of a specific service explicitly requested by the subscriber or user, or for the sole purpose of carrying out the transmission of a communication over an electronic communications network.
Preferences
The technical storage or access is necessary for the legitimate purpose of storing preferences that are not requested by the subscriber or user.
Statistics
The technical storage or access that is used exclusively for statistical purposes. The technical storage or access that is used exclusively for anonymous statistical purposes. Without a subpoena, voluntary compliance on the part of your Internet Service Provider, or additional records from a third party, information stored or retrieved for this purpose alone cannot usually be used to identify you.
Marketing
The technical storage or access is required to create user profiles to send advertising, or to track the user on a website or across several websites for similar marketing purposes.
  • Manage options
  • Manage services
  • Manage {vendor_count} vendors
  • Read more about these purposes
View preferences
  • {title}
  • {title}
  • {title}