A 7-Week Interoperability Intensive for Health Plans and Their Partners


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. CMS has also issued multiple rules relating to health plan obligations and opportunities regarding clinical data access.

Register Today

(Save 50% with code CCHALF)

October 6 – November 18

information blocking for health plans payers

The Sequoia Project’s Clinical Connections: A 7-Week Interoperability Intensive for Health Plans and Their Partners will provide an in-depth study of the Information Blocking Final Rule, and teach you how to understand your potential opportunities and obligations from this rule and how to use it effectively to achieve data access. The Intensive will also explore CMS rules that affect health plan access to and use of clinical data and how these relate to the ONC rules.

The Intensive will consist of virtual meetings, occurring twice a week with one 120-minute interactive classroom lecture and discussion, and one 60-minute open office hours with subject matter experts for student initiated discussion. All participants will also receive an exclusive toolkit, including practical tools for implementation and compliance. The Intensive will provide the opportunity for participants to engage experts and each other in discussing the Information Blocking and CMS rules and how they will affect health plans.

clinical connections interoperability toolkit

What’s Included

  • 7 – 120-minute live, interactive lectures
  • 7 – 60-minute office hours, featuring student-initiated discussion with subject matter experts
  • Compliance and Implementation Toolkit – exclusive resource materials, including practical tools to prepare for compliance and organization-wide implementation
  • Clinical Connections Forum – Private, online discussion forums for students and experts to continue the dialogue between live sessions
  • Clinical Connections Website – Private, online resource bringing together the forum, toolkit, syllabus, class materials, session recordings, class directory, and more.
  • Certificate of Completion


Pay Once, Train The Whole Team

Pay once and bring the whole team! The first employee of each organizaton will be charged full price and then provided a discount code to share with colleagues for them to register for free. Full members of The Sequoia Project can register all staff for no-cost. Each staff member should register using their work email address.

Associate Members &


Per an organization*

*After an employee of an organization registers and pays for the first time, a custom discount code will be provided for additional colleagues to register for no-cost.

Meet the Instructors

Steve Gravely, JD, MHA

Steve Gravely is the founder and CEO of Gravely Group, provides legal and strategic counseling to the healthcare industry, driven by the unique combination of expertise and experience garnered over the course of his career. He has represented healthcare organizations for over 30 years in a full spectrum of healthcare legal issues. Steve is certified by the International Association of Privacy Professionals (IAPP) as a Certified Information Privacy Professional in the United States (CIPP/US).

Mark Segal, PhD, FHIMSS

Mark Segal is Principal, Digital Health Policy Advisors, LLC. He provides strategic counsel to clients on interoperability policy, value-based payment programs, and health IT regulation and patient safety. Previously he was Vice President, Government and Industry Affairs for GE Healthcare Digital. Mark has been a leader and expert participant for health IT-related organizations and policy issues, including standards and interoperability, patient safety and usability, 21st Century Cures, value-based payment and incentive programs, certification, opioids, and delivery system reform.

Mariann Yeager, The Sequoia Project

Mariann Yeager, MBA (Moderator)

Mariann Yeager currently serves as CEO for The Sequoia Project, a non-profit solely focused on advancing secure, interoperable nationwide health data sharing in the US.  She also leads the Recognized Coordinating Entity (RCE) effort, in close collaboration with the Office of the National Coordinator for Health IT to develop, implement, and maintain the Common Agreement component of the Trusted Exchange Framework and Common Agreement (TEFCA) and to operationalize the Qualified Health Information Network (QHIN) designation and monitoring process. The Sequoia Project also serves as a steward of independently governed health IT interoperability initiatives.


Sequoia Project Info Blocking Compliance Bootcamp
Sequoia Project Info Blocking Compliance Bootcamp

2021 Schedule

Oct 6: Overview

3:00-5:00 p.m. ET

This session will provide an introduction to establish the strategic implications for health plans and provide a foundational level-setting of the ONC Final Rule on information blocking as well as CMS rules involving interoperability and clinical data access. We’ll cover the risks and opportunities under the ONC Final Rule, new opportunities for data access and health plan/provider cooperation, and the role of organization-wide compliance and implementation plans for Actors under the ONC Final Rule as well as by other affected organizations, including health plans.

Oct 7: Office Hours

2:00-3:00 p.m. ET

Oct 13: What is an Information Blocking Violation?

3:00-5:00 p.m. ET

This session will explore how an organization could violate the information blocking rules. We will discuss the types of conduct that could get an Actor subject to the ONC rule into trouble and explore the idea of “practices” that could implicate information blocking. We’ll include examples and discuss what ONC has said about such practices, and why this information provides a roadmap for data requesters, such as health plans, to understand data access opportunities and the relevance of compliance planning by Actors.

Oct 14: Office Hours

2:00-3:00 p.m. ET

Oct 20: Exceptions

3:00-5:00 p.m. ET

This initial session on the topic of Exceptions will be an overview of the way ONC organizes the exceptions in the information blocking Final Rule. We will review the role of the elements of the exceptions and what it means to meet an exception and to document compliance. We will begin detailed review of the Preventing Harm, Privacy, Security, and Health IT Performance Exceptions. The discussion of exceptions will emphasize implications and strategies for health plans and other data requesters.

Oct 21: Office Hours

2:00-3:00 p.m. ET

Oct 27: Exceptions Continued

3:00-5:00 p.m. ET

This session will continue with a closer look at Exceptions. We will make a detailed review of the remaining exceptions: Content and Manner, Fees, Licensing, and Infeasibility. We’ll also address interactions and sequencing of the exceptions and continue to emphasize implications and strategies for health plans and other data requesters.

Oct 28: Office Hours

2:00-3:00 p.m. ET

Nov 3: CMS Patient Access Rule

3:00-5:00 p.m. ET

In this session we will provide a detailed overview of the final and subsequent proposed CMS patient access and interoperability rules, including a focus on links to relevant ONC regulatory provisions. We will also address other CMS rules addressing clinical data and interoperability, including those dealing with transparency and “no surprises”.

Nov 4: Office Hours

2:00-3:00 p.m. ET

Nov 10: Enforcement Issues

3:00-5:00 p.m. ET

In this session, we will provide the very latest information on the role of the HHS Office of Inspector General (OIG) to investigate allegations of information blocking, including how OIG will receive complaints and determine which to investigate as well as application of Civil Money Penalties (CMP). A high-level overview of how OIG investigates and what to expect will help health plans prepare for a finalized information blocking enforcement environment. We will also review the legal and regulatory bases for health plans to request data from providers and how these interact with information blocking regulations, including a discussion of provider and patient contracts. Finally, we will cover information blocking enforcementfor providers, the role of ONC certification enforcement for developers, and the implications for health plans.

Nov 15: Office Hours

2:00-3:00 p.m. ET

(Note: This office hours is on a Monday due to the Veterans Day holiday on November 11, 2021.)

Nov 17: Compliance, Organizing for Success, and Wrap-Up

3:00-5:00 p.m. ET

This final session will highlight why an understanding of compliance planning by Actors subject to the information blocking rule is so important to health plans and other data requesters. We will also address compliance planning implications presented by the CMS rules. We will focus on how health plans can organize and plan to respond to the ONC and CMS rules and recap the linkages between the CMS and ONC rules and associated standards (e.g., FHIR and APIs). We will close with a review of the opportunities that these rules provide for increased data access and use as well as for health plan/provider cooperation.

Nov 18: Office Hours

2:00-3:00 p.m. ET

Frequently Asked Questions:

Frequently Asked Questions

Why Should My Staff Complete This Training Now?

Compliance for the Information Blocking provisions of the ONC Final Rule for all Actors (Developers of Certified Health IT, HIEs/HINs, and Providers) is required by April 5, 2020. 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 the April 24, 2020 Proposed Rule). The OIG’s primary timing proposal was for enforcement to begin 60 days after publication of its Final Rule, but no earlier than the ONC compliance date. This proposal is subject to change.

In the face of this uncertainty, and with recognition of the complexity of implementation and compliance planning, a rapidly approaching compliance date, and the acute need for wide data access, The Sequoia Project believes it prudent for organizations subject to the information blocking regulation to target their preparedness efforts on April 5th.

How Does “Pay Once, Train The Whole Team” Work?

Full Members of The Sequoia Project: You may enroll as many employees in the boot camp as you would like. Each team member should register separately using their work email address and the member discount code provided.

Associate Members and Non-Members: Register as an associate or non-member using your work email address. If you are the first person to register from your organization, you will receive a discount code in your confirmation email that may be used by other employees of your organization. These additional employees should register separately using their work email address and this unique discount code.

What Happens If More Than One Employee Pays?

The Sequoia Project will do its best to monitor for duplicate payments from an organization and will contact those impacted to determine best refund method. Please contact if you believe your organization has paid more than once.

Does ONC Endorse This Program?

The ONC does not endorse any outside training program, and this offer from The Sequoia Project is independent from its work as the ONC TEFCA Recognized Coordinating Entity (RCE).

How Do I Login To Participate?

After you’ve successfully registered for the boot camp, you will receive Outlook calendar invitations to all class and office hour sessions. You will also receive a custom URL from GoToWebinar, you will use this same link to login to all sessions.

What If I Miss A Class?

Attendance is required for all classes. However, office hours are optional. To achieve the certificate of competition for the course, please attend all classes live or view the class recording.

All classes and office hour sessions are recorded. The recordings and PDFs of any slides utilized are shared on the course landing page (login required).

Register Now

Clinical Connections

October 6 – November 18, 2021

Skip to toolbar