Will the Preventing Harm Exception cover practices interfering with a patient’s access, exchange, or use of their EHI only for the purposes of reducing an imminent or immediate risk of harm? 

No. The reasonable belief condition does not include a requirement that the harm be expected to occur within a particular time period or that the likelihood of the harm be high enough to be considered “imminent.” (See 45 CFR 171.201(a)). The Preventing Harm Exception’s reasonable belief condition requires an actor engaging in a practice likely to interfere with a patient’s access, exchange, or use of their own EHI to have a reasonable belief that the practice will substantially reduce a risk to life or physical safety of the patient or another person that would otherwise arise from the affected access, exchange, or use.