Blog Post

It's time to comply with ONC's information blocking rule. Here's how to assemble your 'dream team.'

October 13, 2020

    The Office of the National Health IT Coordinator's (ONC) new policy prohibiting information blocking will go into effect on Nov. 2, 2020. As the compliance deadline approaches, health systems are figuring out how to effectively coordinate their efforts. Many health systems tap their IT or Health Information Management teams to lead compliance strategy, adding another "to-do" to a long list of CIO priorities for 2020.

    But your team doesn't have to—and shouldn't—go it alone.

    Why you should set up an information blocking workgroup

    Because the information blocking provision touches many aspects of care delivery and data management, providers must engage a broad range of stakeholders. Leading organizations develop multidisciplinary workgroups to engage compliance, legal, IT, and clinical stakeholders in assessing and addressing gaps in information sharing.

    Beyond having the right stakeholders at the table, information blocking workgroups must assign responsibilities on the team to clarify each role in developing and sustaining your compliance strategy. In the past three months, we've talked to dozens of hospitals and health systems preparing for information blocking compliance. In our discussions, one example of an information blocking workgroup stood out. We want to share this organization's approach to help you assemble the right team for information blocking compliance.

    Who to include in your information blocking workgroup

    To prepare for the compliance deadline, BJC Healthcare—a large nonprofit health system based in St. Louis, Missouri, with 15 hospitals—developed a framework to determine which stakeholders should be included in its information sharing efforts and what they should bring to the table. The BJC Healthcare information blocking workgroup is led by the chief medical information officer (CMIO)/CIO and IT, and it includes representatives from IT, compliance, and clinical backgrounds to support data access. The table below shows the stakeholders who make up BJC Healthcare's workgroup.

    table 1

    What roles your stakeholders should play

    BJC Healthcare's framework goes beyond bringing together key stakeholders. Its workgroup also clearly defines responsibilities for each member of the team. This approach helps minimize redundancy by coordinating compliance efforts across departments and drawing from the stakeholders' existing skillsets/functions. Below are some of the key responsibilities that two stakeholders in BJC Healthcare's information blocking workgroup carry out.

    table 2

    How to assemble your team

    BJC Healthcare laid the foundation for its compliance strategy by assembling an efficient, multidisciplinary workgroup. As your organization prepares for information blocking, keep the following in mind:

    1. Engage stakeholders beyond IT: While many organizations begin with their health information management department, information blocking compliance teams should include a broad range of stakeholders. Ultimately, which departments you start with, and subsequently incorporate, will look different for each organization.

    2. Assign clear responsibilities: To improve efficiency in decision-making and execution of the workgroup strategy, make sure each stakeholder has clear responsibilities for their contribution to the team, based on their existing skills and roles in the organization.

    3. Recognize compliance is ongoing. Have a plan in place to revisit and reevaluate your policies, processes, and IT systems regularly once you have a workgroup in place.

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