Information Blocking
Compliance Resource Center
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Access a growing list of resources.
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Compliance with ONC’s Info Blocking Rule for All Actors is in Effect Now
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). The OIG’s primary timing proposal was for enforcement to begin 60 days after publication of a Final Rule, but no earlier than the ONC compliance date (now extended by five months). This proposal is subject to change.
For Developers
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 closes on April 30, 2022. For more information, see the ONC’s Attestations Fact Sheet.
The second window opens October 1, 2022.


For Developers
As of October 29, 2020, ONC has extended by two months its initial three months enforcement discretion period for information blocking certification provisions (and other certification provisions in its Final Rule).

For Providers
(Who are not subject to ONC oversight or OIG CMPs)
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.
Featured Resources
Rules Education

Information Blocking Rule Summary (PDF)
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Interoperability Matters Information Blocking Workgroup Phase 1 Report (PDF)

Information Blocking Guidance to the Health IT Community (PDF)


Information Blocking Extended Q&A Report (PDF)
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Compliance Education
Understand Enforcement by the Office of the Inspector General
download the report (PDF)

watch the webinar


Compliance Education
Understand Enforcement by the Office of the Inspector General
download the report (PDF)

watch the webinar
The Sequoia Project’s Public Comments
- (PDF) 2020 June – 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
- (PDF) 2020 May – Perspectives on Subpart N-CMPs for Information Blocking of the Interoperability Matters Information Blocking Workgroup
- (PDF) 2019 May – 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 April 5th Compliance Deadline

Information Blocking Compliance Training
*Coming Soon

Information Blocking Comprehensive Compliance Workbook (DOC)
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Additional Resources
Empty Tab to Keep Them Closed
The Centers for Medicare and Medicaid Services Resources
CHIME’s Information Blocking Exceptions 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)
Electronic Health Records Association (EHRA) Resources
Gravely Group Information Blocking Resources
Information Blocking resources and insight from the digital health law firm, Gravely Group
The Office of the National Coordinator for Health IT Resources
CHiME Public Policy Information Blocking Resource Center
Community of Practice

The Sequoia Project
Membership Forum
A perpetual dialogue for members regarding information blocking

Information Blocking
Compliance Discussion Forums
A forum for student discussion for the duration of the virtual boot camp and intensive