Stream: CARIN Benefit Check IG
Topic: Regulatory context
Josh Mandel (Aug 28 2020 at 19:29):
Quick question: looking through https://confluence.hl7.org/display/CAR/RTPBC+Project and the linked resources, I'm not seeing a regulatory mandate for this functionality, just a "broad set of stakeholders, including Congress, CMS, and the White House who have expressed strong support". I wanted to double-check that there's no current requirement to support this kind of capability (with the CARIN IG or otherwise)?
Josh Mandel (Sep 01 2020 at 15:25):
@Ryan Howells do you have a quick take on this? Just want to make sure I'm not missing something.
Ryan Howells (Sep 01 2020 at 18:48):
Great question @Josh Mandel. The answer is not yet, but it's likely coming. More below. . .
In one of the CMS proposed rules (https://s3.amazonaws.com/public-inspection.federalregister.gov/2020-02085.pdf#page=560) it mentions a concept called a beneficiary real-time benefit (RTBT) tool:
As described in section V.G. of this proposed rule, the proposed new paragraphs at §423.128(d)(4) and (5) would require each Part D plan to implement a beneficiary RTBT no later than January 1, 2022. This tool would allow enrollees to view a plan-defined subset of the information included in the prescriber RTBT system which includes complete, accurate, timely, and clinically appropriate patient-specific real-time formulary and benefit information (including cost, formulary alternatives, and utilization management requirements). Plans would be able to
use existing secure patient portals to fulfill this requirement, to develop a new portal, or to use a computer application.
In the final CMS rule (https://www.govinfo.gov/content/pkg/FR-2020-06-02/pdf/2020-11342.pdf) it removes the Beneficiary RTBT requirement, but it does say the topic of a "Beneficiary Real Time Benefit Tool (RTBT) (§ 423.128)" will be addressed under the header: "Requirements to be Addressed Later in 2020". As a result, we are assuming now that we have a published standard (I'm not sure if it's 'official' yet but it's gone through the complete HL7 process), CMS may require a Beneficiary RTBT in the future similar to what the CARIN Benefit Check IG provides.
Ryan Howells (Sep 01 2020 at 22:27):
Ironically, the IG was just published today. Here is the official STU1 version. http://hl7.org/fhir/us/carin-rtpbc/
Last updated: Apr 12 2022 at 19:14 UTC
