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Your guide to the Promoting Interoperability (PI) prevention of information blocking attestation statements

CMS requires hospitals and providers that report to the Medicare and/or Medicaid Promoting Interoperability (PI) Programs, including as part of the Merit-based Incentive Payment System (MIPS), to attest to prevention of information blocking statements. Use the guide to understand what your organization needs to do to attest “yes” to each statement and get our suggestions for documentation to retain in the event of an audit.

What is prevention of information blocking?

A CMS requirement in the PI program that providers have not “knowingly and willfully limited or restricted compatibility or interoperability of their certified electronic health record (CEHRT) technology.”

To whom does this requirement apply?

Hospitals and providers that report to the Medicare and/or Medicaid Promoting Interoperability (PI) Programs, including as part of the Merit-based Incentive Payment System (MIPS).

What do hospitals and providers have to do?

Attest that their CEHRT is implemented and used according to three prevention of information blocking statements. Providers must attest “yes” to all three statements to meet PI program requirements.

How do these statements relate to ONC information blocking?

The scope of the ONC information blocking provision includes, but is not limited to, data elements specified by the PI program. CMS has not yet stated whether they will adopt the ONC definition of EHI and exceptions for the PI prevention of information blocking statements. But the CMS and ONC policies aim to achieve the same overall goal –to support interoperability and stop information blocking. We recommend aligning your approach to the CMS and ONC regulations for consistency. Learn more and get resources to support ONC information blocking in our Information Blocking Toolkit.

Use these resources to help set your strategy.

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