The Centers for Medicare and Medicaid Services (CMS) recently added several FAQs to help providers, facilities, and impacted payers sort through the various provisions of the Interoperability and Patient Access final rule (CMS-9115-F) published in March 2020 to add regulatory teeth to the 21st Century Cures Act. Many of the Cures Act provisions have or will go into effect in 2021, like the new Information Blocking rules which began April 5, 2021. Today, we’ll cover the new Digital Contact Information requirements.
Digital Contact Information Requirements
Section 4003 of the 21st Century Cures Act required that the Department of Health and Human Services (HHS) establish a provider digital contact information index that would include information like a Direct Address, a FHIR server URL, and/or other query endpoints associated with health information exchanges (HIE). This information will allow entities to seamlessly exchange healthcare data, like the new requirement for hospitals to send electronic patient event notifications of a patient’s admission, discharge, and/or transfer to another healthcare facility or to another community provider or practitioner, which went into effect on May 1, 2021.
Since the Cures Act allowed for the use of an existing index, HHS chose to use the National Plan and Provider Enumeration System (NPPES) to meet this requirement. In June 2018, CMS began updating NPPES to be able to capture digital contact information for both individuals and facilities. Those new features included:
- Capability to capture HIE endpoints;
- Ability to maintain information about the type of contact information providers and organizations are associated with and the preferred uses for each address (providers can maintain their own unique information or associate themselves with information shared among a group of providers); and
- A public API which can be used to obtain the digital contact information stored in NPPES.
Consequences for Not Adding Your Info
In the Interoperability and Patient Access final rule (CMS-9115-F), CMS announced that it would begin publicly reporting any providers who do not list or update their digital contact information in NPPES.
“Making the list of providers who do not provide this digital contact information public will encourage providers to make this valuable, secure contact information necessary to facilitate care coordination and data exchange easily accessible,” CMS said in their fact sheet about the rule.
The public reporting of providers was supposed to begin in late 2020 on data.cms.gov. However, CMS indicated that this information would not be published until they have a bulk reporting capability in place. The agency is currently working on an NPPES Electronic File Interchange (EFI) process that will allow for easier bulk updating of digital contact information in NPPES and won’t impact the rest of the provider’s record.
At this time, CMS also has not established a penalty for providers who fail to report their digital contact information, though the agency did say that it may consider penalties as well as incentives in future rulemaking. As well, some providers may be exempt from the reporting requirements. More information about exemptions also will be provided by CMS at a later date.
How to Add Your Data
To add digital contact information to your NPPES record, follow these steps:
- Visit the NPPES website and login.
- Go to the provider you want to update, and select the Health Information Exchange tab on the left.
- Update the following fields:
- Endpoint Type
- Endpoint
- Endpoint Location
- Review and agree to the Terms and Conditions, then save and submit.
- Repeat for all providers at your practice.
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