Two final interoperability and patient access rules granting patients direct access to their health care data as early as July 2021 were published on May 1, 2020, by the Centers for Medicare and Medicaid Services (CMS). The new rules ensure electronic access to patient health information regardless of health system or EHR for CMS-regulated plan types including Medicare Advantage, Medi-Cal, CHIP or the Federally Facilitated Exchanges.
Health plans and health systems will be impacted by these new rules as early as November 2020 and should be efficiently planning and executing now. Technical and operational changes and upgrades will be needed to ensure compliance and avoid penalties.
Read our latest Point of View paper about Interoperability. To learn more about how Freed can help you meet Interoperability requirements, contact us.
What Health Plans Must Do
- Patient Data Access via APIs: By July 1, 2021, health plans must enable patient access to health data using third‑party interfaces via API (application programming interfaces).
- Provider and Pharmacy Directory Access via APIs: By July 1, 2021, health plans must enable access to provider and pharmacy directories using third‑party interfaces via API.
- Payer-to-Payer Data Exchange: By Jan. 1, 2022, by patient request, health plans must be able to send and receive the USCDI clinical data set.
- Member Education: Health Plans must provide member education, especially related to security and privacy.
- Operational Processes: Health plans must design and implement revised and/or new operational processes to support these changes, such as new call scripts to support inbound patient calls seeking help for using a third‑party app.
What Health Systems Must Do
- Information Blocking Compliance: By April 5, 2021, health systems must begin complying with standards for prevention of information blocking, which includes not interfering with access, exchange, or use of electronic health information (EHI).
- Provider Attestation/Digital Contact Updates: By 2021, date TBD by CMS, providers must attest they are acting in good faith regarding prevention of information blocking; non-compliance will be flagged on the National Plan and Provider Enumeration System.
- Admission, Discharge, Transfer (ADT) Event Notifications: By May 1, 2021, hospitals, psychiatric hospitals and critical access hospitals with an EHR must send notifications of a patient’s ADT information to providers.
- Patient Education: The CMS rules call for providing patient education, especially related to security and privacy.
- Operational Processes: Health systems must design and implement revised and/or new operational processes to support these changes.
How Freed Associates Can Help
For almost 30 years Freed Associates has helped health plans and health systems transform their business models to deliver patient and member‑centric, cost effective and sustainable growth. Freed Associates has a multidisciplinary team with expertise to support your organization through strategic planning, data infrastructure modeling, and technology procurement to efficiently address current Interoperability and Patient Access requirements.
Our team excels at:
- Identifying critical considerations for long-term consumer strategy and strategic growth
- Assessing and synthesizing the operational impact of strategic and regulatory change
- Facilitating leadership engagement and alignment on critical initiatives
- Redesigning operational infrastructure to eliminate unnecessary costs and complexity
- Planning and execution of changes to technology platforms and operational processes
- Redefining risk management approaches including security assessments