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Compliance with the Information Blocking provisions of the ONC Final Rule for all Actors (Developers of Certified Health IT, HIEs/HINs, and Providers) was required as of April 5, 2021. The timing of enforcement is less clear. The HHS Office of the Inspector General (OIG) will not finalize its enforcement timetable for Civil Monetary Penalties (CMPs) for Developers and HIEs/HINs pending a forthcoming Final Rule (based on an April 24, 2020 Proposed Rule). This Final Rule is scheduled for Spring 2023 release according to the latest federal government Unified Agenda of Regulatory and Deregulatory Actions. HHS is also expected to publish a proposed rule on provider disincentives in 2023.
The first window for health IT developers of certified heath IT to attest to compliance with the Information Blocking Condition of Certification Requirement opened on April 1, 2022 and closed on April 30, 2022. For more information, see the ONC’s Attestations Fact Sheet.
The second window opens October 1, 2022.
Enforcement timing will depend on forthcoming (but not yet scheduled) rulemaking that will address additional information blocking “disincentives” for Providers as well as the federal agencies to which OIG will refer Provider-focused information blocking complaints.
In the face of this uncertainty, and with recognition of the complexity of implementation and compliance planning, rapidly approaching enforcement rules, and the acute need for wide data access, The Sequoia Project believes it prudent for organizations subject to the information blocking regulation to prepare for enforcement by developing an ongoing, organization-wide information blocking compliance strategy.
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Response to Proposed Rule on Grants, Contracts, and Other Agreements; Fraud and Abuse; Information Blocking; Office of Inspector General’s Civil Money Penalty Rules RIN 0936-AA09
Perspectives on Subpart N-CMPs for Information Blocking of the Interoperability Matters Information Blocking Workgroup
Response to HHS Proposed Rule: 21st Century Cures Act: Interoperability, Information Blocking, and ONC Health IT Certification Program (RIN 0955-AA01)
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A perpetual dialogue for members regarding information blocking
Information Blocking resources and insight from the digital health law firm, Gravely Group
Exception 1: Preventing Harm (June 2020)
Exception 2: Privacy (June 2020)
Exception 3: Security (June 2020)
Exception 4: Infeasibility (June 2020)
Exception 5: Health IT Performance (June 2020)
Exception 6: Content and Manner (June 2020)
Exception 7: Fees (June 2020)
Exception 8: Licensing (June 2020)
Information Blocking Exceptions Companion Guide (June 2020)
Key ONC Interoperability and Information Blocking Timelines (May 2020)
ONC Rule Definitions Cheat Sheet
High-level cheat sheet on the CMS and ONC interoperability final rules (Updated July 2020)
Interoperability Matters a public-private cooperative solving discrete health information exchange challenges through a variety of workgroups and initiatives. Learn More
Workgroup organized to assist understanding the barriers consumers face in accessing health information.
Workgroup organized to help propose and develop strategies to meet consumer healthcare needs.
Workgroup that targets improvements necessary to enable semantic interoperability of health information.
Workgroup focused on the on-the-ground approaches to facilitate information sharing.
Workgroup Inactive Workgroup that explores and recommends methods to improve interoperability amongst payers.
Workgroup that is committed to improving pharmacy interoperability.
Workgroup focused on supporting proper information exchange that protects consumers privacy.
Community of Practice focused on providing participants with best practices at the intersection of public health.
Committee is focused on facilitating and prioritizing the work of the Interoperability Matters Workgroups.
Learn about our history and meet the team that makes The Sequoia Project unique in the healthcare industry
Meet the members that help to make up The Sequoia Project community.
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TEFCA™, outlines a common set of principles, terms, and conditions to support the development of a Common Agreement that helps enable the nationwide exchange of electronic health information (EHI) across disparate health information networks (HINs).
Discover how The Sequoia Project’s Advisory Services can support your organization with tailored projects and provide expert guidance on interoperability initiatives.
Bring The Sequoia Project experts to your organization to deliver education on interoperability and Health IT, tailored to your team’s needs and goals.
Engage The Sequoia Project team to support interoperability and health IT testing initiatives.
Learn how the Data Usability Taking Root Movement is advancing healthcare interoperability by improving the quality, consistency, and usability of shared health data across the industry.
The Sequoia Project is convening privacy & consent advocates in recognition of various initiatives underway to ensure health data is exchanged with proper patient consent.
Role-based education that helps healthcare organizations understand and comply with the Information Blocking Rule established under the 21st Century Cures Act.
The Sequoia Project offers a variety of opportunities for you to promote and highlight your organization throughout the year with sponsorships. From programs to our yearly annual meeting, there are a variety of sponsorship opportunities to choose from.
Discover the latest resources for advancing interoperability in your organization
Explore our public comments on Health IT, interoperability, information sharing, TEFCA, and healthcare policy initiatives.
Share your comments on Interoperability Matters Workgroup draft publications and add your insights to open surveys.
Contact us to learn more about health data interoperability, membership, initiatives, and how to get involved.
The annual meeting is the premier gathering of healthcare leaders, policy experts, and technology innovators dedicated to advancing nationwide health data exchange.
