Data Strategy Briefing — April 5, 2021
Cures Act information blocking provisions took effect for healthcare providers, developers, and HIEs, forcing U.S. teams to operationalize API access, exceptions governance, and complaint handling.
Executive briefing: The information blocking requirements in the ONC Cures Act Final Rule became enforceable on 5 April 2021. Certified health IT developers, health information networks/exchanges, and healthcare providers must now give patients and other actors access to electronic health information (EHI) unless a regulatory exception applies, with ONC and the HHS Office of Inspector General monitoring compliance.
Key interoperability checkpoints
- EHI scope. Expand release processes beyond the USCDI dataset to the full designated record set as defined by HIPAA.
- Exception playbooks. Maintain documented criteria, approvals, and evidence when invoking preventing harm, infeasibility, or content-and-manner exceptions.
- API readiness. Ensure FHIR-based APIs are accessible to patients and third-party apps with transparent registration, authentication, and terms of use.
Operational priorities
- Request intake. Stand up tracking systems for information access requests, denials, and appeals, enabling metrics and root-cause reviews.
- Training. Deliver role-based education for clinicians, HIM staff, and developers on responding to information blocking scenarios.
- Compliance monitoring. Integrate information blocking metrics into governance dashboards and prepare for OIG enforcement when civil monetary penalties become active.
Enablement moves
- Update patient portal content and developer documentation to reflect expanded EHI availability.
- Conduct tabletop exercises using ONC exception scenarios to validate decision trees and escalation paths.
Sources
Zeph Tech supports Cures Act compliance with exception governance playbooks, API readiness reviews, and information blocking monitoring frameworks.