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Repisodic Blog

Sharing insights, impact and successes in our mission to help health systems discharge every patient.

The CMS Interoperability and Patient Access Final Rule Explained


In March 2020, both the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) came out with final rules pushing for more interoperability in patient health data. While the CMS rule–The Interoperability and Patient Access Final Rule–is focused on patient access and control over their health data, the ONC rule–21st Century Cures Act: Interoperability, Information Blocking, and the ONC Health IT–focuses on changing the health information technology and application programming interfaces that will allow patients or other appropriate parties to access the health information. Both of these rules are working to improve the accessibility and interoperability of electronic health information while maintaining and improving necessary security measures over patient information. These rules will give patients more control over their medical information, improve communication between necessary parties in a patient’s health timeline, and promote accountability and transparency.

The premise of the new CMS Interoperability and Patient Access Final Rule is to “help liberate health information and move the healthcare system toward greater interoperability.” To achieve this, the rule prioritizes the patient, involving provisions that give patients access to their health data in a safe and secure way. In the past, accessing health information has caused a number of unnecessary barriers, deterring patients from getting the care they need and making it harder for providers to access a patient’s health history.  When data was not easily or consistently exchanged, getting patient information became arduous. With more information readily available for providers and patients, coordinated care will become easier.

One of the best outcomes of this rule is that patients will have more autonomy over their care.  This will contribute to patients making more informed decisions and having more control over their health, pushing healthcare to become more value based. Additionally, as providers will have better access to this health information, their understanding of their patients will lead to better health outcomes.

With sensitive and private information like health data, CMS has already recognized and adopted the necessary standards about protecting patients. The solution is to use APIs (application program interfaces) that can support the data exchange as well as demand that third-party applications adhere to the strict privacy standards. Using APIs pushes for transparency and innovation: CMS regulated payers must “allow patients to easily access their claims and encounter information, including cost, as well as a defined sub-set of their clinical information through third-party applications of their choice” and providers must make provider directory information publicly available, “allowing third-party application developers to access information so they can create services that help patients find providers for care and treatment, as well as help clinicians find other providers for care coordination, in the most user-friendly and intuitive ways possible.”  With all these changes, CMS wants to educate patients about the implications of sharing their information and protect their rights.

While patients in the past may have been beholden to their payers, this rule allows for patients to access their data from the payer and take it with them to another, allowing for a continuum of care. This helps the patient understand more about the care they are receiving, but also allows the provider to have a more “cumulative health record,” allowing for better diagnosis and health outcome for the patient. With a seamless exchange, CMS believes this will add to better health outcomes for patients. Additionally, this rule updated the current requirements for exchange of data for patients that have Medicare and Medicaid, with intent of “improve the dual eligible beneficiary experience, ensuring beneficiaries are getting access to appropriate services and that these services are billed appropriately the first time, eliminating waste and burden.” 

The coordination of care, which is where Repisodic is involved, takes a lot of cooperation from all parties throughout the timeline of recovery. The transition from hospital to post-acute care facility is extremely important, to ensure that the patient is getting the correct care and prevents unnecessary complications that could lead to a possible hospital readmission.

As part of the new rule, there is a Condition of Participation (CoP) which requires “for all Medicare and Medicaid participating hospitals to send electronic notifications to another healthcare facility or community provider or practitioner when a patient is admitted, discharged, or transferred.” These facilities will have until March 2021 to implement these new requirements. This requirement prevents unnecessary complications that can happen from insufficient communication throughout the transition of care. To keep providers accountable and transparent, CMS has decided to publicly report any type of provider that is not adhering to these standards, is blocking information, or is not updating contact information. This also promotes providers and health care facilities to be more transparent about their costs. With more information available, there is a push to have universal standards.

Through our online platform, Repisodic Choice, we aim to make the continuation of care as seamless as possible. At Repisodic, we know that giving patients access to information goes hand in hand with the information being up-to-date and transparent. Therefore, we have pushed for these changes through specific features in our product. We want patients to choose their care based on correct information about their health and the resources of the post-acute care facility, leading to better health outcomes and faster recovery time.

To read more about this rule, check out the Interoperability and Patient Access Fact Sheet.