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Is Your Organization Prepared for Interoperability Compliance?

Analysis  |  By Mandy Roth  
   January 28, 2020

The Sequoia Project releases a guidebook for the health IT community.

A guidebook to help healthcare organizations prepare for interoperability compliance is now available from The Sequoia Project, a non-profit dedicated to solving health IT interoperability issues.

Guidance to the Community and Implementation Feedback to HHS can be downloaded for free from the organization's website. The publication was prepared by workgroup of 31 representatives from the health information technology sector, including representatives from AHA, AHIMA, AMA, BCBSA, CARIN Alliance, Cerner, CHIME, CommonSpirit, Epic, Google, HIMSS, Humana, Kaiser Permanente, Microsoft, and more.

“This report aims to be a guide for the community,” Mariann Yeager, CEO of The Sequoia Project, said in a news release. “Implementation guidance is essential to reduce uncertainty and prepare for compliance.”

Last February the U.S. Department of Health and Human Services’ (HHS) Office of the National Coordinator for Health Information Technology (ONC) issued proposed rules about information blocking, followed by a public commentary period that resulted in input from thousands of stakeholders. 21st Century Cures Act: Interoperability, Information Blocking and the ONC Health IT Certification Program, was delivered to the Office of Management and Budget (OMB) for review last October. The healthcare community has been sitting on pins and needles since, awaiting the outcome.  

The Sequoia Project provided formal comments to the ONC in May 2019. The new guidebook completes the second phase of the workgroup's efforts, focusing on implementation and implications of the ONC’s proposed rules and potential outcomes, according to the organization.

The publication identifies practical implications of the proposed and final information blocking rules, builds a community of practice around collaborative implementation before and after the ONC final rule, and includes the organization's comments to ONC on the proposed rules, the news release indicates.

Among the observations included in the guidebook:

  • "Compliance is often 'siloed' in different parts of an organization" with fraud and abuse, HIPAA and technology compliance in different departments.
  • "Information blocking cuts across different parts of the organization, which makes compliance a challenge."
  • "It will be a major challenge to shift organizational cultures for HIPAA-related data stewardship to reflect the imperatives to prevent information blocking."
  • A useful starting point for compliance planning, according to the publication, is the HHS OIG Compliance Program Framework, which the guidebook outlines.

The workgroup is now involved in a third phase of the project. Activities will include reviewing the final rule and identifying and addressing priority implementation topics and approaches.

“Implementation guidance is essential to reduce uncertainty and prepare for compliance.”

Mandy Roth is the innovations editor at HealthLeaders.

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