The Office of the National Coordinator for Health Information Technology’s (ONC) 21st Century Cures Act Information Blocking Rule (Info Blocking Rule) prohibits covered actors – including health care providers, health IT developers of certified health IT, and health information exchanges/health information networks– from engaging in practices likely to interfere with, prevent, or materially discourage access, exchange, or use of electronic health information (EHI). The Info Blocking Rule includes eight exceptions that provide actors with certainty that, when their practice interferes with the access, exchange, or use of EHI and meets the conditions of one or more exception, such practice will not be considered information blocking. An actor’s practice that does not meet all the conditions of an exception will be evaluated on a case-by-case basis to determine whether information blocking has occurred.

This resource provides guidance to health centers for implementing FHIR in compliance with the Information Blocking Rule.  

With nearly 100% of community health centers utilizing electronic health records (EHR) to care for patients, focus has pivoted from implementation and new workflow development to enhancement in order to drive value and reflect patient needs and population trends. EHR technology presents potential opportunities and significant constraints. Providers frequently document and share potentially sensitive information in the EHR, such as risk for intimate partner violence (IPV), consistent offers of pre-exposure prophylaxis (PrEP), or patient sexual orientation and gender identity (SOGI). Capturing such information can be immensely helpful in providing care tailored to individuals’ needs, but additionally challenges teams to develop workflows that keep the data private rather than risk harm to patients through improper or unintended disclosure.

Many healthcare providers, including health centers, are concerned about reconciling the need to protect patient privacy under HIPAA and 42 CFR Part 2 while avoiding interference with electronic health information sharing and violating Information Blocking regulations.

As medical care facilities seek to support patient safety and be responsive to their complete medical needs and histories, health centers also recognize that establishing an infrastructure for data sharing must be a top priority. Better practices for Health Information Exchange (HIE) increase patient wellbeing by giving providers more complete information for clinical decision making, eliminating unnecessary procedures and tests, reducing the burden of paperwork, and lowering costs. In 2020, HITEQ interviewed five groups that implemented clinical data sharing infrastructure in health care settings, including Federally Qualified Health Centers (FQHCs). A set of example use cases were developed from these interviews, and we identified ten themes that may help guide other organizations interested in implementing HIE. Information from 1424 qualified health centers and health center look-alikes from the CY2019 Uniform Data Set also informed the current impact of data sharing, indicating that technology and potential workflows exist to support HIE within FQHCs.

View the key considerations gleaned from this research to identify lessons learned related to establishing HIE within a health center setting. The resource is available in the Documents to Download section below.