Health and Human Services’ (HHS) Office of the National Coordinator for Health IT (ONC) released an interim final rule postponing the November 2nd deadline until April 5th, 2021 when Compliance Requirements start for Conditions of Certification:
Information Blocking Assurances: Health IT developers must provide assurances that they will not engage in prohibited Information Blocking (see below)
APIs: We covered API Conditions of Certification in a previous blog: Basically, you need to provide complete documentation, reasonable open access, and publication of fees for your existing API.
EHR vendors (health IT developers) are prohibited from blocking access, exchange, or use of Electronic Health Information (EHI). Eventually (Q3 of 2022), this will extend to include the full HIPAA definition of ePHI. For the April deadline, Information Blocking is limited to US Core Data for Interoperability Version 1 (USCDIv1) and that’s good news for vendors because USCDIv1 is basically the familiar Common Clinical Dataset with a couple of new Data Classes and Data Elements (noted in the table, below):
Think of USCDI as a superset of the CCDS. According to ONC, it “sets a foundation for broader sharing of electronic health information to support patient care”. ONC views the additional Vital Signs as important for pediatric care and Previous Address can be valuable for patient matching.
For those of you certified for 2015 CEHRT, you may be under the impression that you have 24 months after the Final Rule publication date to certify on the new and modified USCDIv1-related criteria:
C-CDA: 170.315(b)(1), (b)(2), (b)(9), (e)(1), and (g)(6)
FHIR: (g)(8) and (g)(9)
You actually have until December 31, 2022 to make certified 21st Cures Act updates for the USCDIv1 dataset available to your customers. But you’ll need a mechanism to output the USCDIv1 data elements for the April deadline and the only two reasonable ways to do this are via FHIR API and C-CDA. So, although you don’t need to re-certify the USCDI-related criteria right now, you’ll want to have the USCDI functionality in place for the April deadline.
As your strategic partner, DHIT strives to stay ahead of regulatory deadlines. We have already undergone ONC Testing for the new (b)(10) EHI Export criterion and the others listed above. Our goal is to ensure you have the tools you need to avoid Information Blocking. Although the deadline has been postponed, we advise to stay the course. It is imperative to upgrade your technology to ensure interoperability support for EHRs, third party apps (see recent blog), healthcare providers and most importantly: patients!.