ACOs Back Hospitalization Alerts in Final Interoperability Rule

March 09, 2020 - Accountable care organizations (ACOs) are calling a new Medicare requirement on hospitalization alerts “a win for better population health management,” the National Association of ACOs recently stated.

Earlier today, CMS released a long-awaited final rule on healthcare interoperability. The final rule largely addressed ways health payers will have to share data with patients, including giving claims data to patients through a new Patient Access API. However, the final rule also included new data sharing and interoperability requirements for hospitals.

The final interoperability rule from CMS will establish a new condition of participation (CoP) requirement for all hospitals participating in Medicare and Medicaid. The new requirement will mandate the hospitals to send electronic notifications to another healthcare facility or community providers when a patient is admitted, discharged, or transferred.

“With this change, ACOs can learn when one of their patients enters or leaves the hospital, allowing that patient’s primary clinician to step in and provide appropriate, well-coordinated care,” NAACOS said in a statement emailed to journalists.

These hospitalization alerts are critical to value-based contract success, according to industry experts.

“You need information on admissions, discharges, ADT feeds, or event notifications so every time a patient registers in the emergency department or gets admitted, transferred, or discharged you get an electronic ping and that’s hitting against that main brain and it is sending information to a desktop,” Christina Severin, president and CEO of Community Care Cooperative (C3), said at Xtelligent Healthcare Media’s Value-Based Care Summit.

This electronic information is key to value-based contract success, the leader of the Massachusetts-based ACO stressed at the event.

Event notifications through admission/discharge/transfer (ADT) feeds were also one of the capabilities successful ACOs had, according to a Health Care Transformation Task Force study of ACOs that have saved money and improved quality of care.

But getting access to electronic information on hospitalizations, transfers, and other events has been a barrier to value-based care success.

Many hospitals have chosen not to share ADT feed alerts with community providers for competitive and other reasons, NAACOS explained in a 2019 letter to CMS. “Advancing regulatory levers to promote Medicare and Medicaid-participating hospitals to share ADT feeds has the potential to significantly improve care for patients across the country,” the association stressed at the time.

But even when local hospitals establish ADT feeds and other event notification systems, challenges remain. For example, accessing real-time data can be impossible for some providers, especially when CMS only provides data on some value-based contracts annually, Michael Ogden, MD, MMM, CPE, also said at the Value-Based Care Summit.

Today’s final interoperability rule from CMS is a step in the right direction for ACOs and other providers engaging in population health management, NAACOS asserted.

“For our health system to move to one that rewards value and supports alternative payment models, providers must be given appropriate data about their patients, and this includes alerts on hospitalizations,” the association stated.

Additionally, NAACOS applauded CMS for adding patient visits to the emergency department in the new CoP requirement, which is slated to take effect six months following the publication of the final rule.

The final interoperability rule from CMS is also going to impact provider workflows in other ways, including participation in the Merit-Based Incentive Payment System (MIPS).

In the rule, CMS finalized a proposal to include an indicator on Physician Compare for eligible clinicians and groups that submit a “no” response to any of the three prevention of information blocking statements for MIPS. The indicator will either be posted on a physician’s profile page or in the downloadable database, starting in late 2020.

Hospitals in traditional Medicare’s Promoting Interoperability will face similar changes, the final rule stated.

Providers have been supportive of the final rules from CMS and ONC but many have expressed concerns with some requirements.

The American Hospital Association (AHA) backed the concept of giving patients access to their own health data. However, the hospital group said the ONC’s final rule “lacks the necessary guardrails to protect consumers from actors such as third party apps that are not required to meet the same stringent privacy and security requirements as hospitals.”

“These guidelines are too important not to get right. We need to stand on the side of the patient by protecting patient privacy and strengthening security in this rule,” the group stressed.