In a Law360 article, health care attorneys analyzed the final rule from the U.S. Department of Health and Human Services Office of Inspector General on civil monetary penalties for information blocking violations and provide compliance considerations.
The authors explain the OIG information blocking enforcement is significant because it introduces civil monetary penalties of up to $1 million per information blocking violation by health information exchanges, health information networks and developers of certified health information technology. The authors also suggest compliance considerations that affected organizations may consider taking to mitigate enforcement risk.
The article was authored by health care partner and co-head of the digital health initiative Christine Moundas and health care associates Gideon Palte and Carolyn Lye.
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