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DATE
ACTION
Jan. 31, 2020
Secretary HHS declares Public Health Emergency
Mar. 4, 2020
CMS announces suspension of non-emergency survey activities
Mar. 6, 2020

Coronavirus Preparedness and Response Supplemental Appropriations Act signed into law.  Waives Medicare telehealth payment requirements. During
Continue Reading Summary List Update of COVID19-related Federal Actions Relevant to Healthcare

On May 1, modifications to the Medicare Conditions of Participation (“CoPs”) went into effect, requiring certain electronic event notifications for admissions, discharges and transfers (“ADTs”) to and from hospitals, critical access hospitals and psychiatric hospitals. To provide guidance to hospitals
Continue Reading CMS Releases Hospital COP Event Notification FAQs; Interpretive Guidance

  • Under the IBR, an HIN/HIN Actor is one that “determines,” “controls,” or has the “discretion to administer” access, exchange or use of EHI between two or more unaffiliated entities.
  • A separate entity is not necessary to trigger the IBR HIN/HIE


Continue Reading When Does a Health Care Provider Wear an HIE/HIN Hat for Purposes of the Info Blocking Rule?

  • On and after April 5, 2021, any Actor’s agreements, arrangements, or contracts are subject to and may implicate the Information Blocking Rule.
  • The Communications Condition of Certification (CCOC) requirements must be revised to remove or void the contractual provision that contravenes the CCOC


Continue Reading NEW ONC FAQ: Prior Agreements or Contracts CAN Implicate Information Blocking as of April 5th!

How can an Actor/covered entity provider comply with both the Information Blocking Rule & HIPAA when access to EHI/PHI needs to be denied based on harm that arises from corrupted data?

  • Delay access to EHI/PHI instead of denying access completely.


Continue Reading Threading the HIPAA Needle through Information Blocking to Block Patient Access when Data is Corrupted

The Information Blocking (IB) Rule is intended to work in sync with HIPAA, including the “right of access” granted to patients with regard to their own protected health information (PHI).  However, as I continue to analyze how to implement the
Continue Reading Threading the Needle on Patient Access after Information Blocking Goes into Effect April 5th