Conditions of Participation

Conditions of Participation

Published: 11/30/2020 – 

Over the past few months, MiHIN has been closely tracking the Center for Medicare & Medicaid Services (CMS) Conditions of Participation (CoP) requirements for Admissions, Discharge, and Transfer (ADT) messages.

When a “final rule,” also known as a regulation, is released from the federal government, it gives agencies the authority they need to impose requirements on certain healthcare players. For example, when the CMS Final Interoperability Rule was released earlier this year, it imposed requirements on payers and hospitals to meet various requirements. One of these requirements placed a mandate on all hospitals, psychiatric hospitals, and critical access hospitals to send ADT messages.

While it may seem straightforward to place a requirement on entities within the healthcare community, the challenge comes when agencies are required to enforce a requirement and track compliance. This is where the CoPs come in. CoPs tie federal funding to compliance with regulations to ensure that entities are meeting their obligations.

MiHIN has reviewed the CMS CoP for ADT messages in detail and has determined that we not only meet, but exceed the requirements placed on hospitals for ADT messages. MiHIN is able to meet the content, manner, and time requirements outlined in the rules. In addition, as a HIN, we are able to help our hospital community exchange ADTs with a wide variety of participants, allowing hospitals to point to HIN participation as proof of compliance.