As the ADA works to support dentists and to advance the oral health of the public, we appreciate the opportunity to work with ONC toward the important goal of a transparent health record and patient-centered care. [...] While we commend ONC for the responsiveness to provider concerns about the schedule of compliance with the rule, for the important content and manner exception to the definition of information blocking, and for the considerable efforts that have been made to explain the implications for providers, many dentists have contacted us with questions about the rule’s applicability to their practice. [...] Additionally, the final rule says that information blocking provisions will begin to apply on April 5, 2021, but the definition of electronic health information (EHI) for purposes of the rule will be limited to the EHI identified by the data elements represented in the U. [...] June 2, 2021 Page 3 In the intervening period between the end of the limitation of the definition of EHI to the EHI identified by the data elements represented in the USCDI and the compliance dates for health IT developers to meet certification requirements, if the content and manner exception is not maintained for actors whose health IT systems are not certified to applicable standards, provider-. [...] We are supportive of the movement towards interoperability, specifically the use of the FHIR as the API Standard and the ability for systems to exchange the core USCDI data elements.
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