Blog from September, 2019

The ISA proposal was submitted, and can be seen at https://www.healthit.gov/isa/sites/isa/files/2019-09/2019_ISA_Comments_Approval_Final%20Submitted_2.pdf

Discussions on preparations for the HIMSS Interoperability Showcase Demo

Review of outstanding specification work

Details on the ISA proposal (due September 23rd):

The list of standards for each of the three sub-sections:

• Closed Loop Referral to Specialist:

  • CDA R2

  • C-CDA 2.1 - in production, highly used

  • 360X - pilot stage

• Referral from Acute Care to SNF
  

  • CDA R2

  • C-CDA 2.1 - in production, highly used

  • 360X - Long term care transfers, request for comments stage

• Closed Loop Referral to Extra-Clinical Services

  • FHIR R4 Observation

  • FHIR R4 ServiceRequest

  • FHIR R4 Task

  • FHIR R4 Messaging

  • BSeR Implementation Guide

The proposal will be distributed on the mailing list, and a sign-up sheet will let participants provide individual or organizational support.

Discussion on updates for the Interoperability Standards Advisory (ISA):

• Currently 360X is under
  • Section II: Content/Structure Standards and Implementation Specifications
    • Summary Care Record
      • Support a Transition of Care or Referral to Another Healthcare Provider
• We need a better presentation. We will propose the following:
  • Under section II create a new sub-section, called "Care coordination for referrals"
  • Within that, list three sub-sections:

    • Closed Loop Referral to Specialist

    • Referral from Acute Care to SNF

    • Closed Loop Referral to Extra-Clinical Services

Discussion on proper handling of clinical data after a decline

• The 360X Implementation guide doesn't say anything, but in demos it is emphasized that after a decline the clinical information is removed from the recipient's system
• The IG doesn't specify anything on that, because it is specific to different situations. If the patient had not been seen by the recipient before the request, then it is up to local or jurisdictional policies what to do with the clinical data. The ability to purge data in this case is a system feature, but no general requirement can be made
• There are cases when it is against  local or jurisdictional policies to purge the clinical data after a decline. In the case of SNFs, the information is needed to justify the decline in the case of an audit.
• Probably needs clarification/short discussion in the IG.

Question about where the reason for cancel is located - it is in ORC-16

A request for sample 360X messages

How does pre-authorization work happen in LTAC transfers? Medicare vs. non-Medicare patients

• Transfer pre-authorization
  • pre-authorization not needed for Medicare patients
  • Most insurance companies have contracts with LTAC facilities, and these transfers do not need pre-auth
  • Only transfers to non-contracted facilities may need pre-authorization
• Medication pre-authorization
  • Medicare patients - since LTAC falls under Medicare Part A, there is no-need for pre-authorizations. Medication treatments are covered under PDPM rules. Note: if the transfer is not to LTAC. but for assisted living, then medications may fall under Medicare part D, and pre-auth may be necessary.
  • Non-medicare patients - private insurance rules vary, pre-authorization may be needed. Sending the coverage information is therefore important, and a clean medication list is critical,
• Based on the above, communicating pre-authorization numbers as part of the request and transfer process is not considered of immediate importance

Initial dates for testing sessions:

• October 17 (and if needed, use the regular call time on the 18th)
• November 5th and November 7th