On March 9, 2020, the U.S. Department of Health and Human Services (HHS) published final rules to implement the information blocking prohibitions of the 21st Century Cures Act (Information Blocking Rules). The Information Blocking Rules take effect on June 30, 2020, although compliance becomes mandatory, in part, beginning November 2, 2020. After May 2, 2022, the rules go fully into effect (until May 3, 2022, the rules apply to a more narrow, but still broad, category of information).
While the new rules affect a variety of entities across the healthcare landscape, this alert highlights some of the important issues specific to healthcare providers when acting as providers. Healthcare providers can also act as developers, health information networks and other entities subject to the Information Blocking Rules, but this alert only addresses their role as providers.