Implementation of CURES ACT

As of 4/5/21 with mandate to be in place by the end of 2022 Sounds to me like our progress notes must be made avaialbe free of charge and immediately to all clients. There is reference to clients needing to have access to an app that can be downloaded to their smart phone (or other device) where they can read their progress notes (psychotherpy notes still protected) with specific detail of what needs to be in each one on the article I attached below amd must be avaialbe immediately to each client.

I am wondering if the Client Portal is sufficient to manage this request or if Pro is planning to do more to align with CURES ACT?

https://www.opennotes.org/onc-federal-rule/