CMS Guidance for Interoperability and Patient Access Rule – Admission Discharge, and Transfer Notifications for Hospitals, Psychiatric Hospitals, and Critical Access Hospitals (CAHs)

On May 7, 2021, CMS sent and advance copy of the Interoperability and Patient Access Rule Interpretive Guidance to State Survey Agency Directors stating the requirements for providers to send electronic patient event notifications.

Under 42 CFR § 482.24, hospitals utilizing electronic medical records system or other electronic administrative system are required to use the system's notification capacities to facilitate the notification of patient admission, discharge and transfer in compliance with state and federal law. At a minimum this information should contain the name of the patient, practitioner, and institution providing care. However, patients maintain the right to privacy and may refuse the sharing of this information. Any refusal should be documented.

The guidance also provides clarification as to when notification should occur. Admission notifications apply to admissions to the emergency department or for inpatient services, and one patient could have multiple admission notifications for treatment. Transfer notifications are applicable for transfers to a different facility or for changes in level of care. Discharge notifications apply to discharges from both inpatient and outpatient treatment. The hospital should make every attempt to send notifications of a patient’s status to all applicable post-acute providers and suppliers. Further, under 42 CFR §§ 482.61 and 435.638, this guidance also applies to psychiatric hospitals and CAHs.

The final rule may be viewed here. A copy of the CMS interpretive guidance can be found here.