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CMS Interoperability Final Rule

CMS Interoperability Final Rule

CMS quietly released its Interoperability & Patient Access Final Rule in March, aiming to provide patients more control over their health information. It is garnering more attention as the deadlines creep nearer. Of particular interest to hospitals is #7, which may require some additional planning and process design. Keep reading for additional resources and the most up-to-date information we have found:

CMS Interoperability & Patient Access Fact Sheet

Seven new policies and deadlines were finalized:

For Payers

  1. Patient Access API: Specified CMS-regulated payers are required to implement and maintain a secure, standards-based (HL7 FHIR Release 4.0.1) API allowing patients to easily access their claims, cost, and encounter information through third-party applications of their choice.   Implementation Deadline:  January 1, 2021
  1. Provider Directory API: Specified CMS-regulated payers are required to make provider directory information publicly available via a standards-based API, to encourage innovation by third-party app developers to help patients find care providers and treatment.  Implementation Deadline:  January 1, 2021
  1. Payer-to-Payer Data Exchange: Specified CMS-regulated payers are required to exchange certain patient clinical data at the patient’s request.  Implementation Deadline:  January 1, 2022.

For States:

  1. Improving the Dually Eligible Experience by Increasing the Frequency of Federal-State Data Exchanges: Updates the requirements for states to exchange certain enrollee data for those individuals dually eligible for Medicare and Medicaid from monthly to daily exchange, aimed at improving the experience and access for beneficiaries.  Implementation Deadlines for States:  April 1, 2022.

For Clinicians & Hospitals:

  1. Public Reporting and Information Blocking: CMS will publicly report eligible clinicians, hospitals, and critical access hospitals (CAHs) that may be information blocking based on how they attested to certain Promoting Interoperability Program requirements.  Implementation Deadline:  Applicable Late 2020 (using data collected in Performance Year 2019)
  1. Digital Contact Information: CMS will begin publicly reporting those providers who do not list or update their digital contact information in the National Plan and Provider Enumeration System (NPPES).  This includes providing digital contact information such as a provider’s Direct Address and/or a FHIR API endpoint.  Implementation Deadline:  Applicable Late 2020.
  1. Admission, Discharge, and Transfer (ADT) Event Notifications: CMS is modifying Conditions of Participation (CoPs) to require hospitals, including psychiatric hospitals and CAHs, to send electronic patient event notifications of a patient’s admission, discharge, and/or transfer to another healthcare facility or to another community provider or practitioner.  Implementation Deadline:  Spring 2021


ADT Event Notifications for Hospitals – What does this mean? 

Ultimately, as a Condition of Participation in CMS programs, this policy creates a requirement for hospitals to demonstrate that they have implemented an electronic ADT notification system to the patient’s applicable primary care provider or other post-acute and/or discharge entity. Per the final rule, CMS states:

‘‘to the extent permissible under applicable federal and state law and regulations, and not inconsistent with the patient’s expressed privacy preferences, the system sends notifications directly, or through an intermediary that facilitates exchange of health information, at the time of: the patient’s discharge or transfer from the hospital’s [or CAH’s] emergency department (if applicable): or the patient’s discharge or transfer from the hospital’s [or CAH’s] inpatient services (if applicable).’’

So there is no measurement or reporting requirement specified at this time. It is simply established that a hospital participating in Medicare and/or Medicaid must be able to demonstrate that they have made reasonable efforts to implement the sending of event notifications to downstream providers of care to patients.

Also see: 

Federal Register, CMS Interoperability Rule, 05/01/2020.  p. 25603

Federal Register, CMS Interoperability Rule, 05/01/2020.  p. 25604


Natalie Stewart


Assistant Director, Quality Services



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