The April 5 compliance date for the Cures Act information blocking final rule (ONC final rule) issued by the Office of the National Coordinator for Health Information Technology is right around the corner for covered actors, which include health care providers, certified health IT developers and health information networks and health information exchanges.

Covered actors should advantage of these final weeks to ensure they are in compliance, with the below steps as a starting point.

• Providers should assess whether their patient portals are configured to provide lab test results and other electronic health information (EHI) to patients without unnecessary delay

• Providers should update release of information policies to ensure that their procedures comply with the ONC final rule (as well as the HIPAA Privacy Rule and applicable federal and state laws)

• Certified Health IT developers should assess whether their contracts and other arrangements with other IT developers and health care providers that involve EHI comply with the Content and Manner, Fees or Licensing Exception (or another exception) to the information blocking prohibition and, if necessary, amend the arrangements to meet an exception

• Certified Health IT vendors should identify steps required to update software to address new ONC final rule requirements for real world testing plans, application programming interfaces (APIs) with new HL& FHIR capabilities, EHI export and other capabilities that come on line in 2021 and 2022