Trends in State, Local, and Regional Health Information Organizations’ Experiences of Perceived Information Blocking, 2019-2025

State, local, and regional health information organizations (HIOs), including HIEs and emerging Health Data Utilities (HDUs), provide health information exchange services to member organizations, who range from hospitals and doctor’s offices to behavioral health clinics and nursing facilities.(1) Because HIOs enable interoperable exchange between healthcare organizations, they are uniquely positioned to directly observe and share their insights on various practices that they perceive to be possible information blocking, including practices of developers of certified health IT, health care providers, and other networks. This data brief presents results from the 2019, 2023, and 2025 National Survey of Health Information Organizations to measure the overall incidence of practices that HIOs perceive may constitute information blocking. The applicability date of the information blocking regulations occurred in April 2021.(2) While identification of whether a practice (an act or omission) constituted information blocking depends on the unique facts and circumstances of the practice, these data can provide a window into HIOs’ experiences about how other entities, like hospitals and health systems or developers of certified health IT, may have engaged in potential information blocking. The data brief provides additional context and understanding of the variation in behaviors that cause friction in the exchange of electronic health information.

Highlights

• The percentage of HIOs reporting any instance of potential information blocking across any actor (developer, hospital and health system, HIO, network) decreased from 2019 to 2025.
• The prevalence of types of potential information blocking practices declined between 2019 and 2025 (though business-related practices that may constitute potential information blocking are still relatively high).
• Potential information blocking is not widespread but instead engaged in by a smaller group of actors.
• The share of HIOs that report routinely experiencing potential information blocking by developers of certified health IT and hospitals and health systems has remained consistent from 2019 to 2025.
• Most HIOs reported that potential information blocking has either a great or moderate impact on information exchange.

The percentage of HIOs reporting potential information blocking across any actor decreased from 2019 to 2025.

Findings

• Seventy-one percent of HIOs reported experiencing any instance of potential information blocking in 2025, down from 91% in 2019.
• HIOs most commonly reported developers of certified health IT as the actor engaging in potential information blocking.
• Half of HIOs reported hospitals and health systems engaging in any type of potential information blocking, a decrease from 2023.
• Few HIOs reported other HIOs/HDUs and national networks engaging in any type of potential information blocking.

Figure 1: Percent of HIOs that reported an entity sometimes or routinely engaged in potential information blocking, 2019-2025.

The prevalence of types of potential information blocking practices declined between 2019 and 2025 (though business-related practices that may constitute potential information blocking are still relatively high).

Findings

• The share of HIOs that report that developers of certified health IT use fees and pricing to potentially block information exchange has decreased from 81% in 2019 to 59% in 2025; however, it remains the most reported potential information blocking practice.
• Nearly half of HIOs report that hospitals and health systems use strategic affiliations—like ownership structures—to potentially block information exchange, which is consistent between 2023 and 2025.
• For both entities, around 1 in 3 HIOs report at least some instances of outright refusal to exchange information.

Table 1: Percent of HIOs that reported developers of certified health IT and hospitals and health systems sometimes or routinely used types of practices they perceived as potential information blocking.

Potential Information Blocking Practice	2019	2023	2025
Developer of Certified Health IT
Price, unreasonable fees	81%	60%	59%
Artificial barriers	65%	49%	40%
Contract language	51%	43%	30%
Refusal	52%	32%	27%
Hospitals and Health Systems
Strategic affiliations	—	45%	42%
Artificial barriers	34%	25%	22%
Refusal	52%	40%	31%

Among HIOs that reported experiencing potential information blocking, most indicated these were not widespread practices by hospitals and developers.

Findings

• Among HIOs that reported experiencing any potential information blocking, the share that indicated some, most, or all developers of certified health IT engaged in potential information blocking declined by almost half (from 55% to 27%) between 2019 and 2025.
• From 2019-2025, about the same share of HIOs—1 in 4—reported that some, most, or all hospitals and health systems engaged in potential information blocking with some fluctuation across years.

Figure 2: Among HIOs reporting experiencing any potential information blocking, percent of HIOs that reported that few, some, or most hospitals and health systems and developers of certified health IT engaged in any potential information blocking, 2019-2025.

The share of HIOs reporting routinely experiencing potential information blocking by developers of certified health IT and hospitals and health systems has not decreased from 2019 to 2025.

Findings

• From 2019-2025, about 1 in 3 HIOs who experienced potential information blocking by a developer of certified health IT reported the behavior was routine.
• From 2019-2025, about 1 in 5 HIOs who experienced potential information blocking by a hospital and health system reported the behavior was routine.

Figure 3: Among developers of certified health IT and hospitals and health systems who engaged in potential information blocking, the percent of HIOs that reported the entity routinely engaged in that behavior.

Most HIOs reported that potential information blocking has either a great or moderate impact on information exchange.

Findings

• In 2025, among HIOs that experienced potential information blocking by hospitals and health systems or developers of certified health IT, about 1 in 5 reported the behaviors had a great impact on information exchange.
• Although the reported impact is increasingly moderate, the share of HIOs that reported potential information blocking had minimal or no impact is unchanged between 2023 and 2025.
• A higher share of HIOs reported that potential information blocking by hospitals and health systems had a somewhat greater impact on information exchange (i.e., missing patient health information) than certified health IT developers (22% vs. 17%).

Figure 4: Percent of HIOs who reported that experiencing potential information blocking affected the missingness of patient health information and their ability to provide health information exchange services to members.

Summary

State, local, and regional health information organizations (HIOs) have long played a crucial role in mediating exchange at the regional, state, and local level, enabling disparate health care, social service, and other entities to connect and exchange information on shared patients and clients. Their role in connecting these entities for different purposes and via different technologies gives them unique insight into how potential information blocking practices affect their operations and prevent more robust information access and exchange. Data collected via the National Survey of Health Information Organizations for years 2019, 2023, and 2025 provide insights into how perceptions of information blocking by HIOs have changed since ONC information blocking regulations went into effect in 2021.(2) The data show that like survey data for hospitals, experiences of perceived information blocking have decreased since passage of the 21st Century Cures Act.(3) Between 2019 and 2025, the percentage of HIOs that experienced any instance of potential information blocking decreased from 91% to 71%. Developers of certified health IT were most commonly reported by HIOs to be engaging in potential information blocking, but the percentage of HIOs that reported potential information blocking by developers decreased from 91% in 2019 to 62% in 2025. Conversely, fewer than 60% of HIOs reported any instance of potential information blocking by hospitals and health systems in 2019, but in 2025, the share has only decreased to 49%, a modest change. However, these rates consider all forms and frequencies of potential information blocking. The forms of potential information blocking HIOs report may provide a deeper understanding of HIOs’ experiences.

Knowing the forms potential information blocking take can be helpful to better craft policy and enforcement actions to deter such practices. The findings show that developers and providers potentially use specific business, market, or other organizational constructs to not share information, rather than just refusing to provide information. Across all years, HIOs reported that developers of certified health IT most commonly used pricing and unreasonable fees to block information flow. In contrast, HIOs reported that hospitals and health systems used strategic affiliations, like organization or ownership structures, to avoid sharing information. This may suggest where efforts might be prioritized to continue to deter information blocking.

Data also show that even though most HIOs report experiencing possible information blocking, a majority of HIOs that experienced potential information blocking indicated that these practices and behaviors are not widespread among hospitals and health systems or developers of certified health IT. Many HIOs, therefore, experienced potential information blocking but increasingly by a smaller group of entities. Furthermore, among those entities who do engage in activities that could potentially constitute information blocking, a consistent share of HIOs reported these specific entities do so routinely. Taken together, this may signal that fewer specific entities may be engaged in potential information blocking, and some share of those entities are consistently doing so routinely.

It’s unknown from the data who these specific entities that are potentially engaged in frequent potential information blocking are. Ongoing work by ONC to encourage reports of information blocking to HHS and educate the community about forms of blocking behaviors may improve awareness and deter these actions in the future.(4) However, as shown in Appendix Table 1, we find that few HIOs make such reports when they do experience potential information blocking. Engagement with the HIO and HDU communities to better understand their experiences and challenges deterring information blocking may also lead to improvements and greater trust in the reporting and investigation process. Although fewer HIOs experience any potential information blocking in 2025, compared to before information blocking regulations went into effect, certain forms of potential information blocking and possibly bad actors remain a barrier to information exchange facilitated and mediated by HIOs and HDUs. Those potential bad actors may have an outsize effect. Most HIOs report that information blocking greatly or moderately affects the missingness of patient health information and operation of information exchange services. Based on these analyses, deterring the small group of actors who may be engaging in potential information blocking practices including those related to business, market, or other organizational constructs to not share information could make a substantial impact on improving information exchange activity among HIOs and HDUs.

Definitions

Health Information Exchange Organization (HIO): Local, regional, and state organizations operating in the United States that supported live electronic health information exchange across unaffiliated entities. This does not include local proprietary or enterprise networks. These organizations may be referred to as HIEs, as well, but their meaning and organizational role remain the same.

Health Data Utility (HDU): Nonprofit organization designed to serve as a public-good infrastructure for secure, statewide health data exchange. Governed by diverse stakeholders and often designated by the state, an HDU supports both public and private sector needs by ensuring access to high-quality, integrated health data in accordance with federal and state privacy laws.

Information Blocking: A practice by an “actor,” undertaken with requisite knowledge, that is likely to interfere with the access, exchange, or use of electronic health information (EHI), except as required by law or specified in an information blocking exception. See the official government website for more information: https://healthit.gov/information-blocking/.

Data Sources and Methods

Data are from the National Survey of Health Information Organizations (HIOs). Since 2019, ONC has partnered with the University of California, San Francisco (UCSF) and the Civitas Networks for Health to track the existence and operations of state, regional, and/or local health information exchange organizations. The data are from the 2019, 2023, and 2025 national surveys. The 2019 survey was fielded from May 2019 to February 2020. In 2019, 106 organizations met inclusion criteria and 89 responded (84% response rate). The 2023 survey was fielded from January to July 2023. In 2023, 90 identified HIOs met the inclusion criteria and 76 responded (84% response rate). The 2025 survey was fielded from January to July 2025. In 2025, 87 identified HIOs met the inclusion criteria and 77 responded (86% response rate).

Statistics are unweighted and exclude missing responses.

Copies of the survey instruments are available on healthit.gov: https://healthit.gov/data/about/#health-information-organization-survey.

Data Availability

Data is available upon request. Please contact ONC_Data@hhs.gov.

References

1. Consortium of State and Regional Interoperability. The CSRI Health Data Utility Capability Model. Available from: https://thecsri.org/the-csri-health-data-utility-capability-model/. Accessed: February 25, 2026.
2. Information Blocking and the ONC Health IT Certification Program: Extension of Compliance Dates and Timeframes in Response to the COVID-19 Public Health Emergency (85 FR 70064). 2020. Available from: https://www.federalregister.gov/documents/2020/11/04/2020-24376/information-blocking-and-the-onc-health-it-certification-program-extension-of-compliance-dates-and#p-69. Accessed: February 25, 2026.
3. Office of the National Coordinator for Health Information Technology. ‘Trends in Hospital Leaders’ Perceptions of Information Blocking’ Health IT Quick Stat #65. Available from: https://healthit.gov/data/quickstats/trends-in-hospital-leaders-perceptions-of-information-blocking/. Accessed: February 25, 2026.
4. Office of the National Coordinator for Health Information Technology. ‘Information Blocking Claims: By the Numbers,’ Health IT Quick Stat #59. Available from: https://healthit.gov/data/quickstats/information-blocking-claims-numbers/. Accessed: February 25, 2026.

Acknowledgments

The authors are with the Office of the National Coordinator for Health Information Technology. The data brief was drafted under the direction of Mera Choi, Director of the Technical Strategy and Analysis Division, Vaishali Patel, Deputy Director of the Technical Strategy and Analysis Division, and Wesley Barker, Chief of the Data Analysis Branch with subject matter expertise from Rachel Nelson, Chief of the Compliance and Administration Branch.

Suggested Citation

Barker W, Healy D, Patel V. Trends in Health Information Organizations’ Experiences of Perceived Information Blocking, 2019-2025. Office of the National Coordinator for Health Information Technology. Data Brief: 85. June 2026.

Appendix

Appendix Table 1: Among HIOs that reported any instance of potential information blocking, percent of HIOs who reported those instances of potential information blocking to the ONC Information Blocking Portal, 2019-2025.

Year	Information blocking practices by developers	Information blocking practices by hospitals and health systems
2025	22%	10%
2023	22%	—
2019	—	—