Information Blocking – What Health Information Professionals Need to Know

Date: October 5, 2022

October 6th, 2022, is the next milestone of the 21st Century Cures Act – when health care providers must provide expedient access to all electronic health information (EHI) as defined within the Designated Record Set.

What is a Designated Record Set?

The term Designated Record Set (DRS) comes from the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule § 164.501 and is defined as follows:

A group of records maintained by or for a covered entity that is:

  1. The medical records and billing records about individuals maintained by or for a covered health care provider;
  2. The enrollment, payment, claims adjudication, and case or medical management record systems by or for a health plan; or
  3. Used, in whole or in part, by or for a covered entity to make decisions about individuals.

What does this mean for health information professionals?  

Health information professionals need to know what information is considered as part of their DRS and how to electronically produce that information when requested.

Haugen recommends three actions to consider:

  • Inventory all ePHI systems and cross reference the information maintained in each system.
    • Evaluate the existing data to determine which records are used in decision making.
    • Understand what method you will need to produce ePHI.
  • Assess the lifecycle of current systems.
    • Identify source of truth to uncover unnecessary and duplicative data
    • Decommission systems to streamline data governance.
  • Review your organization’s DRS definition or create one so that it is clear and concise.
    • Engage all applicable partners and departments in the DRS discussion (HIM, IT, Compliance, Vendors, Legal, etc.).
  • Ensure a process for expedient access to information, when requested.

What if I need more help?

The compliance date is here!  Organizations should take a deeper dive into system inventories and DRS definitions to examine the number of legacy systems still in use.  A legacy system assessment will help identify duplicative data and systems ready for decommissioning.

Haugen Consulting Group has experts in healthcare data that can assist you with your system inventory assessment, creating DRS policies, and assessing legacy systems. We understand the need to access data when you need it and trust the information is accurate and reliable.  Haugen will help conduct a thorough inventory and identify eligible systems for decommissioning to help you create a strong information governance program. Contact us!


Amy Richardson, RHIA, CHDA
Vice President Consulting & Auditing Services | Privacy Officer

Jennifer McCann, RHIA, CHPS, CTR
Senior Consultant

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