How Not to Lose $1M: Preparing for HHS-OIG Info Blocking Enforcement - McDermott Will & Emery

How Not to Lose $1M: Preparing for HHS-OIG Info Blocking Enforcement



The US Department of Health and Human Services Office of Inspector General (HHS-OIG) issued a final rule to implement its authority under the 21st Century Cures Act to investigate allegations of information blocking and assess civil monetary penalties for violations. Certified health IT developers and health information networks or health information exchanges (HIN/HIEs) may face penalties of up to $1 million each time they violate the prohibition on information blocking.

Certified health IT developers and HIN/HIEs should take swift action to ensure their information sharing policies, practices and personnel are prepared for this high-stakes enforcement environment by the final rule’s September 1, 2023, effective date. Join us as we discuss:

  • How HHS-OIG is expected to use its information blocking authority, including the investigation process, enforcement timing and priorities
  • Factors affecting penalty amounts and how certified health IT developers and HIN/HIEs may be able to lower them
  • Anticipated coordination between HHS-OIG, the Office of the National Coordinator for Health IT and other agencies, and how that may shape the enforcement landscape
  • Proactive steps your team can take to prepare for this new era of information blocking enforcement and mitigate risks.

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