March 25, 2021

21st Century Cures Act: Know what's happening with patient notes and test results

In late October 2020, the U.S Department of Health and Human Services (HHS) announced a delay in the compliance timeframes to meet key parts of new federal rules issued by the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC), as part of the 21st Century Cures Act. The rules emphasize that patients are in charge of their health records and mandate that all health systems across the country give them easy, electronic and secure access to their Electronic Health Information.

After this announcement, the team overseeing preparation for the impact of the rules decided to delay VUMC’s rollout of making patient information, such as test results and medical record notes, immediately visible in My Health at Vanderbilt. It has since been working to determine the optimal approach to meeting the new compliance date of April 5, 2021.

The new implementation plan will occur in three stages:

Phase 1: January 20, 20211:

  • Allow clinicians to choose to share in-scope notes with patients (will be defaulted to “do not share”)
  • For all adult patients, immediately release test results2 within My Health at Vanderbilt

Phase 2: February 17, 20211:

  • For all pediatric patients 12 years and younger, immediately release test results2 within My Health at Vanderbilt

Phase 3: March 28, 20211:

  • For all adolescent patients (13-18 years), immediately release test results2 within My Health at Vanderbilt
  • Change default within eStar so that all in-scope notes are automatically shared with patients3

Please note that these changes will only apply to current and future notes; historical notes will not be shared automatically.

A new training module is available in the Learning Exchange.

Information, including FAQs and important links, will be available on the VUMC Interoperability and Information Blocking website: https://www.vumc.org/interoperability. Specific questions may be directed to the team at interoperability@vumc.org.

1 Exact timing to be determined.

2 Test results in very specific instances (i.e., skeletal surveys in young children and Huntington’s disease) are excluded from immediate sharing.

3 Clinicians writing the note may clinically judge that Privacy or Harm exceptions apply. In these situations, the clinician may block the note.