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.

Many health centers struggle to reap the benefits of technological advancement and investments in health information technology (health IT), while others embrace them and reap rewards. Interoperability is one such example; requiring health centers assess systems, relationships, and implementation.

There are keys to successful interoperability implementation for which health centers must develop processes, stand up infrastructure (within the system, internally and externally, and organization), and then take action.

Process refers to structured processes, policies, and procedures within the health center.

Infrastructure refers to structural capacity and ability within the health center’s technology and staffing structure.

Action refers to full implementation to the point of active and ongoing use and engagement.

This scorecard encourages health centers to consider their processes, infrastructure, and action in a number of key areas. Each area key to interoperability are to be self-graded on a scale of 1 through 5, where 1 is poorly or not yet developed and 5 is well developed. Health centers can also use this to guide discussions and monitor progress over time.