ONC’s release of the CURES Act Final Rule in 2020 set many requirements for ensuring that data is at the helm of the patient experience. By outlining specific guidelines and penalties for information blocking, ONC sent a clear message: patients should be able to access their healthcare information, and use that information to make clear, informed decisions with their providers about their healthcare needs. Coinciding with CMS’ release of the Patient Access Final Rule, which mandates the use of FHIR APIs to deliver clinical, claims and provider information directly to patients, transparency and control of patient healthcare data has been transferred from healthcare systems to patients – a shift that strives to ensure improved health outcomes and decreased costs.

Unquestionably well intentioned, the final rules handed down by the federal government have left healthcare organizations, state governments and the tech companies that support them scrambling to meet the aggressive deadlines for compliance. The information blocking rules began in March of 2021, and penalties started being enacted in January of 2022. Policy is slow to adapt, and technology needs to meet states and entities where they are while also helping to drive ambitious goals like transitioning from HL7 to FHIR.

We understand that responding to mandates requires swift action driven by cross-functional teams that bring together policy experts, best-in-class project and product managers, business analysts and technology partners to the table to help states, healthcare organizations and the businesses that support them reach and maintain compliance. Our consultants have supported state Medicaid and health departments, health information exchanges, and health tech startups implement technologies like RESTful APIs that support patient access and limit information blocking – making patient data available when it’s needed. Our unique, team-based approach seeks to bring experts in federal and state policy, developers, project delivery leaders and small businesses together to bridge the gaps in understanding that any one entity may encounter alone. Our Project Management as a Service approach means that we don’t just deliver implementations on time and in budget; rather, we seek to understand the holistic needs of our partners, and respond with the right team to make sure our implementations are optimized for long-term success. We hand off projects when they’re sustainable and give you the tools to scale at your pace.

Meeting regulatory mandates is challenging, and our network of experts knows that bringing the right team together is critical for achieving compliance. Working cross-functionally, we leverage the knowledge of our combined focus in software development, IT implementation, policy expertise, data management and healthcare product management to find the right solution for every client. Whether you’re a state government, health information technology company, a payor, or simply wondering if your company is required to meet any of the specific requirements in the CURES Act Final Rule, we can help make sure you get the right people to answer those questions and help deliver patient data to the hands of those who need it most.


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