Aimed at enabling greater patient access and mandating interoperability, recent Final Rules from the Office of the National Coordinator for Health IT (“ONC”) and the Centers for Medicare and Medicaid Services (“CMS”) have put forth new requirements—which apply to covered entities and certain business associates alike—to reduce information blocking and standardize implementation of multiple Application Programming Interfaces. With the deadlines to implement these requirements quickly approaching, covered entities and applicable business associates need to consider the necessary overhaul of health information technology infrastructure and other protocols to comply with the Rules. This summary provides the purposes behind the Rules, noteworthy insight culled from public comments and responses published in the Federal Register, key requirements of each Rule, and action items for organizations that are responsible for carrying out the new requirements. The detailed action items, coupled with comprehensive coverage requirements of each Rule, provide a framework for covered entities and business associates to begin evaluating their current protocols and determine the fastest path to compliance with the recent ONC and CMS Rules.
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