by Madison Agee
Vanderbilt University Medical Center is working toward a Nov. 1 date to comply with key parts of new federal rules issued by the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC), as part of the 21st Century Cures Act.
The rules place strong emphasis on putting patients in charge of their health records and mandate that all health systems across the country give patients easy, and secure, electronic access to their Electronic Health Information.
In particular, the new rules explicitly prohibit “information blocking,” which is defined as any activity that delays or limits patient access to their electronic medical records.
While there are a few exceptions that do allow some level of information blocking, those are quite rare and will only be implemented in extraordinary situations.
VUMC has established a cross-functional team to help ensure we are ready to comply with the rules by Nov. 1.
The team comprises representatives from various teams across the organization, including Patient Experience, Health Information Management (HIM), HealthIT, Revenue Cycle, Office of Legal Affairs (OLA), and clinical operations.
These teams have been working diligently over the last several weeks to understand the implications of the rules and how best to prepare the Medical Center for their impact.
Because this intense preparation is happening both in a year in which VUMC has dealt with the effects of the COVID-19 pandemic and in a relatively short timeframe, the team has engaged outside counsel to help interpret some of the rules and help direct necessary action. While many workstreams have already been mapped in detail, there are some that are still pending additional direction from these external legal experts.
The rules require that VUMC:
- Provide patients with access to many parts of their own medical record
- Release nearly all lab, radiology and pathology results into My Health at Vanderbilt with no time delay
- Update clinician information in critical federal databases
- Share health information with certain authorized parties, including insurance companies, employers and patients’ smartphone apps
Much of this work has been under discussion for several years at the Medical Center and significantly precedes the direction of the final rules.
Many VUMC leaders have championed putting patients more in control of their own health care by giving them better access to their medical record.
“The concept of Open Notes is not a new one for us at VUMC,” said Chief Patient Experience Officer and Chief Medical Officer Paul Sternberg Jr., MD.
“In many ways, we’ve been simply waiting for the right moment to make it a reality for our patients. The release of the final rules has only accelerated our efforts and put some regulatory power behind them.”
As additional information is finalized — for example, around any types of clinical exceptions that would delay test results — the team will share the details. Currently, efforts are underway to confirm these decisions and determine the best way to make them operationally successful at VUMC.