CMS Conditions of Participation Compliance (C3) Support

What Arizona Hospitals Need to Know

Arizona’s health information exchange (HIE) has developed the CMS Conditions of Participation (CoP) Compliance (C3) Support services to assist hospitals in meeting the new CMS Patient Event Notifications requirement. The HIE is well positioned to serve as an intermediary to help your organization meet the new CMS requirements.

HIE C3 Support services include:

  • Alerts (i.e., Patient Event Notifications)

  • CMS CoP Compliance (C3) Report

  • Recruitment Collaboration

Through leveraging existing technical infrastructure between hospitals and the Arizona HIE and expanding capabilities to engage and connect with primary care and post-acute providers, Contexture can help organizations adhere to CMS requirements.


In May 2020, the Centers for Medicare & Medicaid Services published the CMS Interoperability and Patient Access final rule that adds a new CoP for hospitals. In an effort to support the care continuum, CMS will soon require hospitals to alert primary care providers (PCPs) and post-acute care providers (PACs) when patients are admitted, discharged or transferred (ADT) from the emergency department (ED) or inpatient services. Whereas CMS refers to these alerts as Patient Event Notifications, they are commonly recognized as ADT alerts.

The new requirement applies to hospitals (including psychiatric hospitals and critical access hospitals) that participate in Medicare or Medicaid and have an electronic system using HL7 version 2.5.1 or newer. This is typically the patient registration system, which can be a stand-alone administrative system or part of an electronic health record (EHR) system.
Hospitals with these technical capabilities must use reasonable efforts to send real-time alerts — directly or through an intermediary, such as an HIE — to the patient’s PACs and PCPs who need to receive notification of the patient’s status for treatment, care coordination or quality improvement purposes.

Non-compliance may threaten a hospital’s certification and ability to recoup payments from Medicare and Medicaid. Therefore, it’s critical that hospitals understand the updated CoP and have a plan in place to meet the technical and administrative requirements.

Hospital Compliance Under New CoP

CMS Certification is critical for hospitals because it determines whether they receive CMS payments. CMS payments make up a significant portion of the hospital’s payer mix. A hospital must meet all CoP requirements in order not to jeopardize its certification.

Under the new CoP, a hospital must demonstrate that:

  • Its system is fully operational and operates in accordance with state and federal laws for health information.

  • Its system sends the minimum patient information, including patient name, treating practitioner name and sending institution name.
  • Its system sends the ADT alerts either directly or through an intermediary at the time of ED registration or inpatient admission, and either immediately prior to or at the time of discharge/transfer to the providers specified in the CoP.
  • The hospital has made a reasonable effort to send the ADT alerts to all the providers specified in the CoP to the extent it is:

    • Permissible under applicable federal and state law and regulations
    • Not inconsistent with the patient’s expressed privacy preferences

Using Intermediaries to Meet the ADT Alert Requirements

The new requirements expressly permit hospitals to send ADT alerts through an intermediary that facilitates the exchange of health information, such as an HIE.

Get Started

To learn more about our C3 Support services, contact Peter Steinken, director of community engagement, at or 602-464-9641.