• Your vendor is not “taking care of it.” Compliance with the Information Blocking rule is about more than just the technology.
  • Assemble a “task team” to tackle operational decisions that need to be made to comply with Information Blocking.
  • Use a checklist to begin “ticking off” boxes to ensure that your organization is moving towards compliance with Info Blocking by April 5th!

Subscribe to HERE to Legal HIE’s compliance library to gain access to sample policies, documents and tools for compliance with the Information Blocking Rule.

Over the last few weeks, I have come across a number of health care provider organizations that are under the incorrect assumption or belief that their EMR vendor is “taking care of” all that needs to be done in order for the provider to comply with Information Blocking. This is false. Although a significant part of the Information Blocking Rule does include new requirements for health IT developers to successfully obtain ONC certification or recertification in the future, including alignment with compliant information blocking practices, there are operational decisions and other process issues that must be addressed and can only be implemented by the Actor – i.e., the health care provider organization or HIE/HIN, as applicable.  So, every health care provider that meets the definition of an “Actor” should be taking active steps towards getting their organization positioned to comply with Information Blocking by April 5, 2021. Where should you start?  I propose using a checklist as a simple starting point to begin “ticking off” your Information Blocking “to do” list — and, good news . . .  I have put one together for you here to get you started!

Completing all of the items on this list does not guarantee your organization’s compliance with Information Blocking, which will be determined by other considerations including your organization’s health IT functionality and types of requests for EHI being received.  Nevertheless, I think that it offers a good-enough skeleton to build off of as you dig deeper into your Information Blocking compliance efforts.  Enjoy!