Information Blocking Compliance BOOT CAMP

Compliance with the Information Blocking provisions of the ONC Final Rule for all Actors (Developers of Certified Health IT, HIEs/HINs, and Providers) is required as of April 5, 2021.

The Sequoia Project’s Information Blocking Compliance Boot Camp will provide an in-depth study of the Information Blocking Final Rule, and teach you how to develop effective implementation plans and compliance measures.

The Boot Camp will consist of virtual meetings, alternating weekly between 120-minute interactive classroom lecture and discussion, with 60-minute open office hours with subject matter experts for student initiated discussion. All participants will also receive the exclusive Boot Camp toolkit, including practical tools for implementation and compliance. The Boot Camp will provide the opportunity for participants to engage each other in discussing the Information Blocking rule and compliance.

What's Included:

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, 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 including the Patient Unified Lookup System for Emergencies (PULSE) and the RSNA Image Share Validation Program.


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 with their membership discount code. Each staff member should register using their work email address. 





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.

2021 Schedule


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

This session will provide an introduction and C-suite/governance team orientation to establish the strategic implications and provide a foundational level of the Final Rule. We’ll cover the risk and opportunities under the Final Rule, and the need for both compliance and organization-wide implementation plans.


3:00-4:00 p.m. ET


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 you into trouble and explore the idea of “practices.” We’ll include examples and discuss what ONC has said about practices, and why this provides a roadmap for your organization’s compliance planning.


3:00-4:00 p.m. ET


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 Final Rule, and what we can infer from the changes made between the proposed and final rule. We will review the role of the elements to 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.


3:00-4:00 p.m. ET


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.


3:00-4:00 p.m. ET


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

In this session, we will examine the role of the Office of Inspector General (OIG) for allegations of information blocking, including how they will receive complaints and determine which to investigate. We’ll also review Civil Money Penalties (CMP), and the impact to you if they apply – or don’t – to your organization. A high-level overview of how OIG investigates and what to expect will help your organization to prepare. Finally, we will cover enforcement agencies for providers and the role of ONC certification enforcement for developers.


3:00-4:00 p.m. ET


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

This initial session on Compliance will lay the foundation for why compliance planning is so important, including how to identify your organizations risk and develop documentation. We’ll cover approaches to compliance programs, including in-house versus outsourcing, and how to use the OIG Compliance Framework as a guide.


3:00-4:00 p.m. ET


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

(Note: This class will be on a Tuesday)
This final session will be a more in-depth and practical discussion of how your organization can implement information blocking compliance programs, whether integrating information blocking into your existing compliance program or as a new program. We’ll also have tips for overcoming obstacles to implementing such a compliance program within your own organization.


3:00-4:00 p.m. ET

Frequently Asked Questions:

If you missed the 2020 Information Blocking Compliance Boot Camp, The Sequoia Project will re-offer the program in 2021. The anticipated dates are each Wednesday at 3:00 p.m. ET from January 20th to April 21st. The pricing structure will remain the same as 2020.

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.

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.

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.

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. 

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).