By the EHR Association Information Blocking Compliance Task Force

This is the first installment of a multi-part blog series on the EHR Association’s analysis of the HTI-5 proposed rule.

The HTI-5 proposed rule, Health Data, Technology, and Interoperability: ASTP/ONC Deregulatory Actions To Unleash Prosperity, significantly updates information blocking compliance provisions. The proposed changes raised red flags for the EHR Association because they do not provide the simplification, guidance, and education needed to cut through the complexity of current policy. In fact, they increase the complexity and challenges of compliance.

Also among our overarching concerns are ASTP/ONC’s apparent overstatement of the burden-reduction outcomes of its proposed changes and its underestimation of the true economic impact of both the current information blocking policy and the proposed changes, as implied by the agency’s failure to provide an estimate of the implementation costs borne by the industry. The reality is that the proposed changes will increase the administrative burden on software developers and other stakeholders who interact with our community in the process of determining the best path forward for information access, exchange, and use.