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Information Sharing & Regulatory Compliance

Resource Center - Archive

Looking for information sharing strategies? Access a growing list of resources.

Members of The Sequoia Project receive access to helpful forums.

Compliance with ONC's Info Blocking Rule for All Actors is in Effect Now

For Developers

For Providers

(Who are not subject to ONC oversight or OIG CMPs)

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.

Archived Resources

Rules Education

Compliance Education

Understand Enforcement by the Office of the Inspector General

HHS OIG Proposed Rule on Information Blocking Enforcement & Monetary Penalties Overview

The Sequoia Project's Public Comments

2020 June - PDF

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

2020 May - PDF

Perspectives on Subpart N-CMPs for Information Blocking of the Interoperability Matters Information Blocking Workgroup

2019 May - PDF

Response to HHS Proposed Rule: 21st Century Cures Act: Interoperability, Information Blocking, and ONC Health IT Certification Program (RIN 0955-AA01)

Compliance Toolkit

Prepare for Information Blocking Compliance

Community of Practice

The Sequoia Project Membership Forum

A perpetual dialogue for members regarding information blocking

Additional Resources

Gravely Group Information Blocking Resources

Information Blocking resources and insight from the digital health law firm, Gravely Group

CHIME's Information Blocking Expection Toolkit

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)

American Medical Associaion Information Blocking Resources