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3:25-4:15 p.m.

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An Overview of Information Blocking Rules

Presenters at this session will review key aspects of the Information Blocking rules published by CMS and the Office of the National Coordinator of Health Information Technology (ONC HIT). Both rules will have significant impact on health information management professionals that manage patient records and data. They will also discuss acceptable and non-acceptable practices related to the sharing of electronic health information as defined in these rules. They will review how they impact interoperability and discourage excessive fees that may be associated with connectivity between health information applications.

The 21st Century Cure Act defines information blocking as a practice by a health care provider, health IT developer, health information exchange, or health information network that, except as required by law or specified by the Secretary of Health and Human Services (HHS) as a reasonable and necessary activity, is likely to interfere with, prevent, or materially discourage access, exchange, or use of electronic health information (EHI).

Presenters will provide examples of practices that may or may not rise to the level of information blocking. They will discuss strategies designed to reduce the risk of noncompliance and substantial financial penalties.
They will also review activities that have been identified in these final rules that represent actions consistent with information blocking. These include implementing technology in a way that restricts, delays, or otherwise discourages access to EHI, including but not limited to opportunistic pricing practices.

Presenters will review reasonable and necessary activities that would not constitute information blocking if information were to be withheld. These include but are not limited to actions that protect patient safety, patient privacy, and the security of EHI. The rules also allow for the recoupment of reasonable costs and licensing fees, and organizations are not obligated to respond to infeasible requests.

Learner Outcomes

Attendees of this session will:

• Gain an understanding of the relevant HIM components of the information blocking rules released by CMS and the Office of the National Coordinator of Health Information Technology (ONC HIT).
• Learn about the practices covered by the information blocking rules.
• Understand the potential penalties associated with noncompliance as part of the new information blocking rules.
• Learn about impactful changes specific to the CMS final rule.
• Understand impactful changes specific to the ONC final rule.
• Learn about when it is acceptable to withhold information or to charge fees for information under the information blocking final rules.


Michael Stearns, MD, CPC, CRC, CFPC
Apollo HIT, LLC Austin, TX
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