Compliance Timelines ASCA encourages all ASCs to visit and familiarize them- selves with the exceptions. Although ASCs often have less health IT infra- structure than hospitals or physician offices, they might still store data that is considered EHI under this rule and could, therefore, be subject to penalties if they are not compliant with requests for access, exchange or use of EHI. Luckily, this rule has extended compliance timelines to give stake- holders time to prepare for meeting the new standards. At press time, the final rule still had not been published in the Federal Register. Once the rule is pub- lished, stakeholders have six months to prepare for compliance, but stake- holders will only be responsible for a limited definition of EHI for the first 18 months, i.e., the period of six to 24 months after publication in the Federal

Register. From 24 months after pub- lication and onward, full compliance would be required. The extended compliance timeline

should give ASCs time to prepare. It also is important to note that OIG car- ries responsibility for enforcement of the Information Blocking rule. They will delineate processes for assessing infractions and applying penalties in separate rulemaking.

ASCA EHR Advocacy At this time, there is no ASC-specific EHR certification. While some ASCs use EHRs in their facilities, many ASCs still find it financially unviable to pro- cure and implement an EHR, much less a module certified to ONC standards. In 2017, ASCA convened a group

of stakeholders from within the ASC community to discuss advocacy and education regarding EHRs in ASCs.

The group holds regular calls that cover pertinent legislative and regula- tory changes and provides an avenue to generate educational opportunities, resources and general discussion. A smaller workgroup, comprising ASCA staff, vendor affiliates and member representatives, also meets periodi- cally and is working toward creating a voluntary, ASC-specific EHR certi- fication. This certification would pro- vide a baseline for EHR vendor system development and allow ASCs to par- ticipate in new, value-based care mod- els. ASCA staff maintains contact with staff at ONC and continues to advocate for ASC-specific standards.

Alex Taira is ASCA’s regulatory policy and research manager. Write him at ataira@


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