Information Blocking Avenger

This spreadsheet developed by the HITEQ Center provides a crosswalk of Clinical Quality Measures and their electronic specifications as defined in the 2023 update for Eligible Professionals (Clinicians). Fields include the crosswalk of measures with related information about CMS, NQF, and MIPS ID, and Telehealth Eligibility, as well as inclusion in HRSA BPHC Uniform Data System (UDS) CY2023, Million Hearts, CMS Quality Payment Program (QPP) - Performance Pathway (APP) Measures, Medicare Shared Savings Program (MSSP)/ CMS ACO Shared Savings Program, CMS Core Set (Child Core Set Medicaid / CHIP): HEDIS Specified, CMS Core Set (Adult Core Set Medicaid): HEDIS Specified, Core Quality Measures Collaborative (ACO / Primary Care). Links are included throughout.

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.  

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.