Do the information blocking regulations require actors to have or use certified health IT, or upgrade the certified health IT they already have, in order to fulfill a request to access, exchange, or use electronic health information?

No. The information blocking regulations do not require actors to have or use health IT certified under the ONC Health IT Certification Program. Actors subject to the information blocking regulations are not required to immediately upgrade their certified health IT (as of the applicability date (i.e., April 5, 2021)) if they also happen to participate in a separate regulatory program that requires the use of certified health IT, such as CMS’ Promoting Interoperability Programs.

Please review the questions under the "Electronic Health Information" heading for more information.