The CMS ADT Rule Takes Effect May 1, 2021. Are You Ready?
The new CMS rules are upon us, and they are here to stay! Centers for Medicare and Medicaid Services (CMS) announced a deadline of May 1, 2021 for their new admission, transfer and discharge (ADT) notification requirements. A part of their larger Interoperability and Patient Access rule, it applies to all hospitals, including behavioral health and critical access hospitals (1). This initiative signals a shift in thinking that will benefit patients, encourage collaboration amongst providers and improve healthcare outcomes.
The goal of the CMS Interoperability and Patient Access rule is to encourage a more seamless data exchange in healthcare while giving patients better access to their health data and records. As a part of this larger initiative, electronic notifications are required for all ADT activities. The objective of this mandated communication between providers as their patients move in and out of the hospital is to reduce re-admissions resulting from lack of adherence during post discharge care programs. In short, CMS wants to limit instances of patients and their care plans getting lost as they move between facilities and within the community.
Healthcare, like so many data heavy sectors, is rife with disconnected systems which cannot or will not communicate with each other. While there are standard communication protocols that can bridge these gaps, cost along with conflicting priorities have prevented their widespread implementation. As a result, patients move from one closed electronic system to another with limited communications, leaving precious data behind, often with detrimental health impacts. The ADT rules are a clear attempt to force closed systems to start communicating. This is a move in the right direction for patient data and health outcomes and is likely just the beginning.
First, let’s break down the ADT rule specifically and what this means for your organization from a technology perspective:
ADT Rule and Technical Compliance Explained:
The CoP (condition of participation) applies to all hospitals whose EHR system or electronic administrative system is “conformant” with the HL7 2.5.1 content exchange standard (1). HL7 (Health Level Seven) is an internationality recognized set of standards for transfer of clinical and administrative data between provider systems. Fast Healthcare Interoperability Resources (FHIR) is a standard derived from HL7, so you will often hear the two terms together. They have become the industry standard for healthcare data sharing, and most EHRs support both. With this in mind, CMS’ CoP is reasonable and casts a wide net – hospitals will have a tough time claiming they can’t participate.
For participating organizations, the challenge of ADT is architecting and implementing the communications infrastructure. Because the CoP targets hospitals, they will decide the how and what of the data sharing, pushing communications out to providers. Initially, implementation will be a broadcast communication defined by hospitals to meet the requirements of ADT alone.
As stated in the rule, hospitals must demonstrate that they shared the information with appropriate providers in a timely manner (1). However, there is an important stipulation – hospitals must build the HL7 data feed and must ensure they are sharing the relevant patient data, but they are not responsible for ensuring that the data is received or acted upon.
The natural next step is for CMS to mandate providers to prove that they received the ADT notifications and, ultimately, that they acted upon them. CMS uses the word “exchange” in the ADT rule language and technical requirements. This clearly foreshadows a future where hospitals are not only notifying providers but ingesting relevant patient data as well.
What’s Next…
The immediate result of requiring hospitals to communicate ADT related patient data with providers is that no patient should be left behind. Currently patients are given paper instructions to follow-up with their GP or specialist, but now those instructions will be accompanied by an electronic notification and the relevant data.
With notifications mandated, the next step is ensuring GPs and specialists are receiving those notifications and following up with patients to ensure post-discharge monitoring and management happens in a timely manner.
The future is where the care continuum truly comes to life, with patient data traveling seamlessly with, or even ideally ahead of, the patient from admission to transfer or discharge and beyond. This data continuum allows providers at all points on the patient journey to access real-time, relevant data for informed decision making. What are now electronic walled gardens become a steady stream of information ensuring better patient outcomes.
The final piece is remote patient monitoring (RPM) data. As technology advances and connected medical devices become commonplace in homes, phones and watches, RPM insights will feed into the river of patient data as well. RPM gives providers a rich view into a patient’s health, an easy way to identify red flags, and the ability to stage early interventions accordingly.
At the core of the ADT Rule is “giving patients better access to their health data and records (2).” With this shift to patient-centric data sharing, CMS is acknowledging the current themes of health equity and the “whole person” approach to healthcare. This rule doesn’t necessarily solve all the issues of health equity, but it’s a step towards ensuring that patients don’t “get lost in the system”.
The shift from walled garden to flowing stream of data is where platforms like Mozzaz have an obvious role. At the provider level, Mozzaz connects disparate provider EHRs ensuring data moves seamlessly along the care continuum. For patients, we provide engaging and personalized one-stop access to their health data while offering RPM through connected devices. Putting the patient at the center is the core of what we do with a “Follow-the-Patient" digital engagement model.
The CMS ADT rule is launching our industry into the future of the care continuum; relevant, real-time data shared across disparate systems with the patient at the heart. Interested in learning how Mozzaz can help your organization prepare for the new CMS initiative and more? Contact us, today.
References
(1) How Hospitals Comply with the ADT CoP Requirement: Part I. (2021). EHR Intelligence. Retrieved from https://ehrintelligence.com/news/how-hospitals-comply-with-the-adt-cop-requirement-part-i#:~:text=October%2026%2C%202020%20%2D%20With%20the,%2C%20and%20transfer%20(ADT)%20event
(2) Interoperability and Patient Access Fact Sheet. (2020). CMS.gov. Retrieved from https://www.cms.gov/newsroom/fact-sheets/interoperability-and-patient-access-fact-sheet
