Federal policy efforts to advance health data exchange and interoperability are continuing to change rapidly. The latest changes are the publication of two final rules by the Assistant Secretary for Technology Policy/Office of the National Coordinator for Health Information Technology (ASTP/ONC) finalizing parts of the Health Data, Technology, and Interoperability (HTI-2) Proposed Rule. These rules adopt requirements regarding the Trusted Exchange Framework and Common Agreement (TEFCA) (HTI-2 Final Rule), and create a new Information Blocking exception under Protecting Care Access (HTI-3 Final Rule), published on December 16th and 17th, respectively.

The HTI-2 Final Rule focuses on changes to CFR Parts 170 and 171, finalizing updates to the Privacy and Security Framework criterion and certification, information blocking regulations including definitions related to the TEFCA Manner Exception, and several administrative updates. This regulation comes in the wake of recent policy developments released by the Recognized Coordinating Entity in coordination with ASTP/ONC. This rule is effective on January 15, 2025.

HTI-3 Final Rule finalizes proposals related to reproductive health data and information blocking regulations, including modifications to the existing information blocking exceptions (Privacy Exception and Infeasibility Exception) and a new information blocking exception (Protecting Care Access). This rule was effective upon publication.

The release of HTI-2 and HTI-3 Final Rules is intended to advance interoperability and support the access, exchange, and use of electronic health information. We note that there are a number of proposed changes with regards to health IT certification that were not finalized. We expect that ASTP/ONC will continue to work on these changes with the intent of finalizing them in 2025.

For more information, please see our client alert summarizing the most relevant components of HTI-2 and HTI-3 Final Rules.

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Photo of Jodi G. Daniel Jodi G. Daniel

Jodi Daniel is a partner in Crowell & Moring’s Health Care Group and a member of the group’s Steering Committee. She is also a director at C&M International (CMI), an international policy and regulatory affairs consulting firm affiliated with Crowell & Moring. She…

Jodi Daniel is a partner in Crowell & Moring’s Health Care Group and a member of the group’s Steering Committee. She is also a director at C&M International (CMI), an international policy and regulatory affairs consulting firm affiliated with Crowell & Moring. She leads the firm’s Digital Health Practice and provides strategic, legal, and policy advice to all types of health care and technology clients navigating the dynamic regulatory environment related to technology in the health care sector to help them achieve their business goals. Jodi is a contributor to the Uniform Law Commission Telehealth Committee, which drafts and proposes uniform state laws related to telehealth services, including the definition of telehealth, formation of the doctor-patient relationship via telehealth, creation of a registry for out-of-state physicians, insurance coverage and payment parity, and administrative barriers to entity formation.

Photo of Tai Williams Tai Williams

Tai is an associate in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Dispute Resolution and Health Care groups.

As a member of Crowell’s International Dispute Resolution Group, Tai has experience advising investors in complex cross-border investment arbitrations.

Tai is an associate in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Dispute Resolution and Health Care groups.

As a member of Crowell’s International Dispute Resolution Group, Tai has experience advising investors in complex cross-border investment arbitrations. She also represents foreign and domestic clients in Foreign Sovereign Immunities Act (FSIA) and Anti-Terrorism Act (ATA) litigation, which includes victims of terrorism around the globe.

As a member of the Health Care Group, Tai counsels and represents managed care organizations, insurers, health care providers, and health care technology companies in various regulatory, transactional, and litigation matters. She works with health care entities seeking to comply with federal and state laws and regulations, including those related to fraud and abuse.

Photo of Eunice Lalanne Eunice Lalanne

Eunice Lalanne supports Crowell Health Solutions, a strategic consulting firm affiliated with Crowell & Moring, to help clients pursue and deliver innovative alternatives to the traditional approaches of providing and paying for health care, including through digital health, health equity, and value-based health…

Eunice Lalanne supports Crowell Health Solutions, a strategic consulting firm affiliated with Crowell & Moring, to help clients pursue and deliver innovative alternatives to the traditional approaches of providing and paying for health care, including through digital health, health equity, and value-based health care. She is a health care policy consultant in the Washington, D.C. office.