Information Blocking

What We Know

• In March 2020 the Office of the National Coordinator (ONC) published the 21st Century Cures Act final rule.
• This includes prohibition of "information blocking" in an electronic health record.
• Failure to comply with regulations will result in financial penalties.
• Deadline for compliance is April 5, 2021 (previously the deadline was November 2, 2020)
• Who is affected – All systems with an EHR, Health Care Providers, Health IT Developers or Certified Health IT, Health Information Exchanges and/or Health Information Network

What We Have Already Done

• Contra Costa Health Services went live with data sharing through MyChart on 10/14/2020
  *MyChart is a patient portal within ccLink, our Electronic Health Record (EHR)
• Behavioral Health Services began sharing the Partnership Plan through MyChart on 11/2/2020
• Behavioral Health Services has reached out to DHCS and have verified guidance that the mental health documentation is included and should be shared as well as the rest of the medical record, with the exception of psychotherapy notes
• An info blocking subcommittee within BHS has been meeting regularly to prepare for the April 2021 deadline
• Behavioral Health Services is updating and finalizing our Policies and Procedures as they pertain to information blocking and release of information
• On March 23, 2021 the BHS Info Blocking subcommittee sent out a ccLink tip sheet with instructions on how to 'unshare' notes and document the relevant harm exception
• On April 5, 2021, BHS will began to share sharing the following through MyChart:
  • Clinical Notes (BHS Assessment Note, BHS Progress Notes, BHS Group Notes and BHS Annual Update)
  • BHS Discharge Summary
  • BHS Network Provider Services – Service information including date, location, type, and name of individual outpatient provider for the network vii.
  • BHS CBO Provider Service - Service information including date, location, type, program and contract provider

Next Steps

In order to meet the October 6, 2022, deadline for sharing EHI (electronic health information) beyond the USCDI data elements, the BHS subcommittee will work to define the designated record set for BHS client records. This will include identifying all systems and areas in which patient information lives as well as determining the custodian for each piece of information.