Seeing is Believing: A Real-World Take on CMS' Interoperability Proposal

CMS announced a long-awaited interoperability proposal designed to improve patient access to health data and care coordination back February.

What will it mean to real-world healthcare settings?

One of the most meaningful proposed changes is adding a requirement to the Conditions of Participation for Medicare hospitals to share ADT (admissions, discharge, and transfer) data for electronic patient event notifications.

The benefit of sharing ADT transactions across thousands of providers would be impactful immediately and the proposed changes would formalize CMS’ care coordination efforts, sending the message that care coordination is integral to improving patient care.

Making Data Exchange More Meaningful

Since ADT data is generated in real-time as patient care is being delivered, it enables providers to leverage the data for timely patient interventions. Providers can act on the alerts created by shared ADT transactions to ensure that their patients are receiving the appropriate level of care and avoid unnecessary rehospitalizations. For example, primary care physicians are often currently unaware when one of their patients is hospitalized. If the primary care physician can receive real-time alerts when one of their patients has been admitted to a hospital, the physician can then follow the patient during their hospital stay and ensure that a follow-up appointment is scheduled post-discharge.

ADT notifications are a critical first step. However, when given access to ADT notifications, many providers quickly ask for clinical context. We shared this in our comments to CMS and suggested that they consider requiring the sharing of patient diagnosis, for example, right off the bat. Patient diagnoses, especially new ones, help to convey a more complete picture of patient health to providers on the receiving end. Other examples of helpful clinical context to enhance the utility of the ADT notifications would be prior history of hospitalizations or previous stays in post-acute care settings, medication lists, and care team contacts.

Extending Data Exchange Beyond Hospital Inpatient Units

Taking it a step further — including settings beyond inpatient units of hospitals such as emergency departments in the final rule – would have manifold benefits for the patient. For example, a physician who sees his or her patient re-presenting to the ED after having just been discharged from a nursing home may reach out to the ED and suggest that the patient be transferred to the nursing home for follow-up rather than a full admission to the hospital. This way, a patient has better continuity of care and avoids a costly readmission.

The kind of coordinated care described here only happens when providers can follow the patient from the moment he or she presents in the ED, through admission to the hospital, and discharge to the nursing home.

Closing the Loop to Hold Stakeholders Accountable

Through its many value-based care programs, CMS has indicated that accountability is key to effecting change in the healthcare industry.

One area of concern with the current version of the interoperability proposal is how to hold providers accountable for sharing ADT data. For example, how do we reward providers that are sending and receiving notifications on all of their patients, versus the providers that are satisfying the requirement for only 1% of their patients? How do we ensure that receiving providers are acting upon the information rather than immediately hitting delete? The proposal is silent on what mechanism will be employed for measuring success.

To ensure that critical patient information doesn’t fall through the cracks, we need to measure the effectiveness of the sending and receiving of information. In our comments to CMS, we surface the issue of accountability and suggest that CMS create a closed loop process.

CMS’ proposal is an important step toward furthering interoperability. These notifications can ensure that millions of patients receive high value and coordinated care. We strongly support the agency’s efforts of connecting providers across the continuum and facilitating the sharing of real-time information.

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