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ACCESS requires HIE connectivity and structured care updates; PCPs must receive start/escalation/completion notices
Summary
CMS said ACCESS participants must send standardized, HIPAA‑compliant care updates to PCPs at care start, clinical escalation and completion, connect to a CMS‑aligned network or HIE by July 5, 2027, and obtain beneficiary consent for proactive sharing.
CMS presenters outlined how ACCESS aims to strengthen coordination between Access participants and primary care clinicians by requiring standardized care plan templates, secure transmission methods and HIE connectivity.
"Before sharing these updates, Access participants must obtain the beneficiary's consent to proactively share care updates with their identified PCP and referring clinicians," said Anna Rabel, Access Model Quality Lead. She added that updates must be transmitted via HIPAA‑compliant methods such as direct secure messaging, health information exchanges (HIEs) or secure e‑fax.
Minimum timing requirements for required updates specified by CMS: - Within 10 days of submission of all baseline OAP measures: care plan, baseline measures, responsible contact and initial care goals. - Within 30 days after the end of the 12‑month care period (or sooner if alignment ends): summary of outcomes, medications and follow‑up recommendations. - Within 10 days of any transition of the beneficiary to another practitioner or care setting due to clinical needs exceeding ACCESS services.
Access participants must establish connectivity to an HIE or CMS‑aligned network (or an equivalent trusted network) by July 5, 2027, to support structured updates and provider queries. Presenters emphasized that connectivity should support bidirectional exchange across the participant’s service areas.
CMS also noted that participants must document steps taken to identify a beneficiary’s PCP or referring clinician during enrollment; if a PCP cannot be confirmed, the requirement is met and the participant should refer the beneficiary to a suitable in‑person or telehealth primary care provider if needed.
