Lexology September 29, 2025
Key Takeaways:
- HHS indicates that information blocking enforcement is a priority and on the horizon.
- Permanent Medicare telehealth flexibilities remain elusive.
- Part 2 compliance obligations loom, with OCR as the new enforcement sheriff in town.
- State laws may impact compliance with information blocking and artificial intelligence regulations.
Information Blocking Crackdown
Earlier this month, the U.S. Department of Health and Human Services (HHS) published a press release announcing a “crackdown on health data blocking” as the HHS Secretary had directed HHS to “increase resources dedicated toward curbing the harmful practice of information blocking.” As discussed in our previous client alert, the Information Blocking Rule (IBR) prohibits certain entities (including healthcare providers and developers of certified health IT) from blocking...







