CMS/ONC Open Notes Requirements

September 21, 2021

Some NYS Council members may recall our having discussed a new federal interoperability requirement from CMS and ONC that seeks to shift the way the healthcare systems share data, moving from a system where the organizations may share data under HIPAA to one where they must share data through the use of Open Notes.

Linked here please find a PowerPoint presentation prepared by our colleagues at the National Council for Well Being for Association Executive Directors across the country.  I attended the presentation given by Dr. Joe Parks, Medical Director for the National Council earlier.  I wanted to pass along the slide deck.

In addition, here is the recording of the presentation for Association Executives regarding the Open Notes requirement:

While several key dates associated with this requirement have come and gone, the federal government appears to be taking a phased in approached to compliance.  At the present time, there are no penalties being enforced by the federal government on providers who have missed the initial dates (see slide #5).  Having said this, it is important to review the information in the slide deck and begin to strategize as an organization as to how you will implement these new requirements.

As you will see, impacted agencies that require their clinicians to utilize collaborative documentation (also know as concurrent documentation) will have a leg up in this implementation.  Collaborative Documentation is a process in which clinicians and clients collaborate in the documentation of the Assessment, Service Planning, and ongoing Client-Practitioner Interactions (Progress Notes). If you would like more information on the use of this technique, please let me know.

See the Power Point presentation and please do not hesitate to contact me for further information.