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CMS Releases Guidance on Interoperability Rule

The Center for Medicare & Medicaid Services (CMS) May 7 released interpretive guidance related to CMS’ interoperability and patient access final rule published in May 2020. The guidance includes information on hospital admission, discharge, and transfer notification requirements outlined in the final rule.

The interoperability and patient access final rule revised the Medicare conditions of participation to require hospitals to electronically exchange information with other health care facilities or community providers in the form of electronic event notifications on a patient’s admission, discharge, or transfer. The requirements are applicable to all patients registered in the emergency department or who receive inpatient services. Discharge notifications would be applicable for all patient discharges from either inpatient or outpatient admissions.

CMS believes the requirements, effective May 1, improve care coordination by allowing a receiving provider, facility, or practitioner to reach out to the patient and deliver appropriate follow-up care in a timely manner.

The interpretive guidance instructs:

  • hospitals with an electronic health records system or electronic patient registration systems to use the system’s notification capacity to facilitate notification of patient admission, discharge, and transfer information in accordance with state and federal law;
  • hospitals, upon consent, to include in the information exchange the name of the patient, practitioner responsible for treatment, and name of the institution providing care; and
  • make every attempt to send notifications of the patient’s status to all applicable post-acute providers and suppliers, in addition to the patient’s primary care practitioner, primary care group, or other practitioner or group that is identified by the patient.

Hospitals that do not have electronic administrative systems are not required to comply with this standard.

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Abigail Painchaud is a policy associate at America's Essential Hospitals.

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