Plain-English statement. Retinex Health does not impose any practice that would interfere with the access, exchange, or use of Electronic Health Information (EHI), except where required by law or permitted under a published exception in 45 CFR Part 171, Subparts B and C.
Summary
The Information Blocking rule (45 CFR Part 171) prohibits practices by health IT developers, health information networks, and providers that are likely to interfere with the access, exchange, or use of EHI, unless the practice fits a defined exception. Retinex Health is a certified Health IT developer and is subject to HHS OIG civil money penalties for information-blocking violations.
What Counts as EHI
Under 45 CFR 171.102, EHI means electronic protected health information (ePHI) to the extent it would be included in a designated record set (DRS) as defined at 45 CFR 164.501. Psychotherapy notes and information compiled for legal proceedings are excluded.
Retinex’s definition of the DRS for export purposes is documented in the EHI Data Dictionary.
No-Blocking Commitments
- We provide single-patient and patient-population EHI export at §170.315(b)(10) certification scope.
- We do not gate export functionality behind contractual concessions unrelated to lawful security and HIPAA requirements.
- We publish this documentation, the data dictionary, and the archive format publicly, at no charge, with no authentication required.
- We do not throttle exports, impose volume caps, or delay delivery to discourage interoperability.
- We do not condition data access on use of Retinex-specific tooling or services downstream.
Applicable Exceptions
Where Retinex limits the manner of access, exchange, or use of EHI, we do so only under a published exception in 45 CFR Part 171, Subparts B and C:
| Exception | Citation | When Retinex may rely on it |
|---|---|---|
| Preventing Harm | 45 CFR 171.201 | Withholding EHI where release is reasonably likely to endanger the life or physical safety of an individual. |
| Privacy | 45 CFR 171.202 | Withholding EHI in compliance with HIPAA Privacy Rule or state privacy law (e.g., 42 CFR Part 2 substance-use records). |
| Security | 45 CFR 171.203 | Reasonable, technically tailored measures to protect EHI confidentiality, integrity, and availability. |
| Infeasibility | 45 CFR 171.204 | When fulfillment is not technically feasible because of an uncontrollable event or segmentation limit. We document each such determination in writing. |
| Health IT Performance | 45 CFR 171.205 | Planned maintenance windows that briefly impact access. Communicated in advance via System Status. |
| Manner | 45 CFR 171.301 | Fulfilling a request through a substitute interoperable manner when the requested manner is not feasible. |
| Fees | 45 CFR 171.302 | Any cost-recovery fees, if applied, comply with this exception. EHI export under §170.315(b)(10) is free. |
| Licensing | 45 CFR 171.303 | Any licensing of interoperability elements is non-exclusive and offered on RAND terms. |
Fees
EHI export under §170.315(b)(10) is provided at no charge to patients, providers, and successor systems. See the Cost and Fees section of the EHI Export documentation for the full statement.
Complaints & Reporting
If you believe Retinex Health has engaged in information blocking, you may:
- File a report with HHS OIG via the ONC Information Blocking Portal at healthit.gov/feedback.
- Contact us directly at support@retinex.ai and we will respond within five business days.