On February 11, 2019, CMS issued a proposed rule supporting its MyHealthEData initiative to improve patient access and advance electronic data exchange and care coordination throughout the healthcare system. The Interoperability and Patient Access Proposed Rule outlines opportunities to make data more useful and transferable through open, secure, standardized, and machine-readable formats while reducing restrictive burdens on healthcare providers.
Provisions in this proposed rule would improve care coordination for dually eligible individuals by addressing the interoperability and exchange of health care information. While most of the proposed regulations are broadly applicable, two provisions propose to increase the frequency of state-CMS exchange of dual eligibility data. The first proposes daily state-CMS exchange of data to identify who is enrolled in Medicare, and which parties are liable for paying that beneficiary’s Parts A and B premiums. The second proposes daily state submission of Medicare Modernization Act (MMA) files (which identify all full-benefit and partial-benefit dually eligible beneficiaries). Currently, states and CMS exchange these data as infrequently as monthly in many states, which delays enrollment status changes, and leads to inaccuracies, recoupments, and poor customer experiences. Improving the accuracy and timeliness of data on dual eligibility status is a strong first step in improving how these systems work together for beneficiaries, providers, and payers. Both provisions would take effect April 1, 2022.
The proposed rule also includes a request for stakeholder input for consideration in future rulemaking on how CMS can achieve greater interoperability of federal-state data for dually eligible beneficiaries, including in the areas of program integrity and care coordination, coordination of benefits and crossover claims, beneficiary eligibility and enrollment, and their underlying data infrastructure.
An unofficial copy of the proposed rule is available at https://www.cms.gov/Center/Special-Topic/Interoperability-Center.html. For the provisions specific to dually eligible individuals, please see Section VII (Improving the Medicare-Medicaid Dually Eligible Experience by Increasing the Frequency of Federal-State Data Exchanges) and proposed changes to regulatory text in Parts 406, 407, and 423.