Interoperability Standard Revisions

Did you get a chance to read our May issue of the Patton Post?  If so, you likely will remember seeing that we had two separate sections on “Interoperability.” This seems to be a current Hot Topic with the accrediting agencies due to the continuing “feedback” they are receiving. We encourage you to review the interoperability standard revisions.

Interoperability Standard Revisions

How well does your EMR / EHR (electronic medical / health record) system work and does it do what is required? 

The Joint Commission (TJC) and Centers for Medicare and Medicaid Services (CMS) have both respectively revised and issued guidance on the topic.

Let’s break it down…

TJC Standard Changes

IM.02.02.07 EP5, requiring the notifications that the hospital must send to aftercare providers. 

There are two changes from the May 2021 Perspectives notice to pay attention to:

1. The wording they used previously was “as applicable” and now the requirement says “all applicable.”
2. The addition of the phrase “as well as any of the following” (including the same list of primary care practitioners, primary care group or practice, and other practitioners or practice groups the patient identifies as primarily responsible for their care).

CMS Interpretive Guidance Requirements:

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

There are three A-tag requirements to note:

1. A-0470 (requires notice be sent for registration as an inpatient or emergency room patient to external providers)
2. A-0471 (requires notice be sent to post-acute providers when a patient is discharged from the hospital)
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).

This likely will be the subject of discussion among hospital attorneys prior to the effective date at the end of June, so you will want to share this QSO memo with your IT department and attorneys ASAP.  You will want to verify that you are ready to send these notices if using your current EMR / EHR system.

Patton Healthcare Consulting

For more information on interoperability standard revisions, view our May issue of the Patton Post or contact us for more information on how to implement.  Our TJC and CMS experts are here to help!