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Coming into compliance with the Information Blocking Rule

Adam H. Greene ( is a Partner in the Washington, DC, office of Davis Wright Tremaine LLP and cochair of its Health Information Practice Group.

On April 5, 2021, the 21st Century Cures Act Information Blocking Rule will become applicable.[1] In practice, this means that information-blocking actors—healthcare providers, health information technology (IT) developers of certified health IT (health IT developers), and health information networks and health information exchanges (HIN/HIEs)—are required to assess and revise longstanding information practices in order to appropriately free up electronic health information (EHI). While the applicability date is fast approaching, many questions remain. When will enforcement begin? What are the proactive obligations for compliance? What practices that do not fall under exceptions nevertheless qualify as “reasonable”? This article will identify some of the most vexing questions surrounding the Information Blocking Rule and offer strategies for compliance among this uncertainty.

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