Health Information Exchange & Interoperability Resource Sets

Sample Information Blocking policies, procedures, and templates

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Tools for Health Centers to Comply with Rules Prohibiting Information Blocking

Steps in using sample information blocking policies, procedures, and templates from HITEQ:

(available for download at the bottom of this page)

 

  1. Conduct Initial Information Blocking Risk Assessment (Appendix A) as part of the organizational record, and update annually thereafter.
  2. For any organizational practices that appear on the list of suspected practices for Information Blocking (Appendix A, Section VI)
    1. Record the exact practice and current workflow, and assess whether any of the 21st Century Cures Act ONC exceptions apply using Appendix D: Information Blocking Exceptions and other references. 
    2. For any practices that are reviewed where no exceptions apply, cannot be modified, and is/are necessary, document that the organization does not intend for the practice to result in information blocking.
  3. Develop/review policy/ procedure for reviewing/fulfilling requests for information.
    1. Ensure that process is non-discriminatory and expedient.
    2. Ensure that electronic and physical information requests are consistent in terms of consent, privacy, and legal requirements.
  4. Develop a process for documenting exceptions to requests
    1. Ensure that process aligns with the eight possible exceptions, noting that five allow for not fulfilling the request while the other three refer to procedures for fulfilling requests.
    2. Use other HITEQ information blocking process resources, including Appendix D: information blocking exceptions
  5. Implement documentation for exceptions on a case-by-case basis
  6. Develop a process for responding to requests, either where information will be shared and access maintained or where the request will not be fulfilled, and the reason needs to be communicated. 
  7. Review and adopt information blocking complaint procedures (Appendix E)
    1. Use Appendix G as a template for investigation workflow.
    2. Use Appendix H to document the investigation.
  8. Document complaints, incidents, and related responses and/ or actions
    1. Use Appendix F - Incidence Response Log to document this.

Download all of these documents below.

Disclaimer: Information blocking forms become part of the record and can be reviewed by OIG during an investigation. The HITEQ Center and related entities are not liable for any direct or indirect consequences resulting from information given herein and advises legal counsel review of these and all forms prior to use.

The HITEQ Center project is supported by the Health Resources and Services Administration (HRSA) of the U.S. Department of Health and Human Services (HHS) as part of awards totaling $779,625 with 0% financed with non-governmental sources. The contents are those of the author(s) and do not necessarily represent the official views of, nor an endorsement, by HRSA, HHS, or the U.S. Government. For more information, please visit HRSA.gov.

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Acknowledgements

This resource collection was compiled by the HITEQ staff with portions contributed by Mr. Dan Tuteur, the Colorado RHIO, OCHIN, and the Sequoia Project.

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