By Liz Buckle, DirectTrust Program Director

DirectTrust is pleased to announce the formation of a Notifications Consensus Body within DirectTrust Standards to address the ADT Notifications Conditions of Participation from the CMS final rule

The publication of the CMS patient access and interoperability final rule this past May has many EHR vendors and their customers pondering their strategy and what solution(s) they’ll have in place to meet the Conditions of Participation (CoPs) by May 2021. For those serving inpatient or acute settings, how will they send these notifications at admission, discharge, and transfer? How will they know where to send and how to get the messages there? How will outpatient, ambulatory, post-acute, or long-term care facilities receive notifications? 

There’s a clear intent that stakeholders plan to guide their customers to use Direct Secure Messaging as a key solution to meeting the notifications CoPs.  

Leveraging the Direct Standard™ provides an obvious starting point due to the breadth of adoption of Direct technology due to Meaningful Use and its iterative programs, along with the ability to set up with relative ease and the availability of 2.4 million trusted addresses in the DirectTrust network. However, even with a solid framework underneath, there are still outstanding questions on how to accomplish the goal of sending and receiving notifications via Direct in a manner that makes it easy for the sender to know where the messages should go, and for the receiver to prevent alert fatigue.

One of the biggest questions is what is the content – the payload? Sending Direct messages with a C-CDA attached is the norm, but is it the right answer for notifications? Some may be considering the use of simple text without an attachment, while others require an attachment to be able to process the inbound message. 

What is the right amount of content and what is too much? 

The next question, additionally as important, is how do we manage subscriptions? If the goal is to avoid alert fatigue, identify recipients, and for recipients to have some level of configuration over what they want to see, then some type of subscription must be in place. Minimally, the messages need to indicate in the metadata what type of event has taken place, but there’s an opportunity to expand beyond just the event type to include more information that can be used to manage subscriptions. 

With all of these questions swirling around, it became clear very quickly that DirectTrust needed to convene a group of key stakeholders to define the expectations for the broader community.. The Notifications Consensus Body, which will launch in September 2020, will focus solely on writing a Notifications implementation Guide that will provide answers to these questions. It’s imperative that the industry take ownership of the creation and consensus-building process for the Implementation Guide. 

Let’s be clear – we do not propose through the formation of this Consensus Body that we create something brand new. 

Recognizing the hard work that has been done in this space, the intent is to define and agree upon how to use what exists to meet the Conditions of Participation for those who are required to do so, and to allow the receivers to know what to expect and be able to adjust in accordance with those expectations. 

DirectTrust welcomes and encourages the work that other industry initiatives are doing in this space – including our friends and peers at Carequality, CommonWell Health Alliance, and Da Vinci, for example. 

We recognize that Direct technology may be one of several solutions for notifications and want to ensure that those who want to use Direct Secure Messaging to send and receive notifications have a clear pathway to success. 

FAQ about the Notifications Consensus Body:

Q: Why is DirectTrust convening a new Consensus Body? 

A: DirectTrust is convening a new Notifications Consensus Body in order to respond to the many industry questions that have been raised both in ad hoc conversations and within the EHR Roundtable forum regarding how users should leverage Direct Secure Messaging to send and receive notifications in accordance with the CMS final rule. DirectTrust is an ANSI approved Standards Development Organization and therefore wants to facilitate efforts of the industry experts to solve this problem while maintaining openness and balance in the development process of creating an Implementation Guide. 

Q: What are the goals of the Consensus Body? 

A: The goal of the Notifications Consensus Body is to create an Implementation Guide that leverages the existing Direct Standard™ to provide additional guidance specifically on the payload requirements, and the use of context in metadata, so that subscriptions can be managed by configurations by the sender and/or receiver, and so that messages can be routed based on those configurations. 

Q: How fast will the standards process go? 

A: The process to reach a draft Implementation Guide for trial use can and will go as fast as the stakeholder participants want it to go. We recognize that the Consensus Body likely needs to move quickly so that stakeholders can begin to act on the outcome with enough time to be prepared for the May 2021 date. DirectTrust is willing and able to support meeting as much as the Consensus Body participants desire – including facilitating all-day events if necessary. DirectTrust will adhere to the American National Standard process to ballot the Standard in accordance with our Procedures.

Q: Why is this separate from the Direct Standard Consensus Body? 

A: We initially considered having the current Direct Standard Consensus Body take on this effort, but recognizing that the current Direct Standard Consensus Body is already convening on other important topics, and that the Notifications work has a clear timing requirement, it was necessary to convene a separate Consensus Body. We also recognize that there may be stakeholders who participate in the Notifications Consensus Body due to the nature of their business who might not need to play a role in the Direct Standard Consensus Body. 

Q: Do we have to have a balloted Standard to implement? 

A: No. Many standards have been implemented and used by stakeholders while still in draft form. We expect that stakeholders will want to act quickly and implement the guidance from the draft Implementation Guide once it reaches agreement in the Consensus Body and before it’s officially approved as a Standard. 

Q: Who can participate in the Notifications Consensus Body? 

A: Any interested stakeholders can participate.  All DirectTrust members and DirectTrust Standards members can participate in the new Notifications Consensus Body at no additional cost. Stakeholders who are not already DirectTrust members or Standards members can participate through one of these three methods:

  1. Become a DirectTrust member
  2. Become a DirectTrust Standards member 
  3. Consensus Body participant, per person, per organization 

For more information, please visit the Participate in DirectTrust Standards page or contact standards@directtrust.org