Manatt Health July 19, 2021
Alexander Dworkowitz, Michael S. Kolber

After a six-month delay due to the COVID-19 pandemic, the first provisions of the interoperability rule issued by the Centers for Medicare & Medicaid Services (CMS) took effect on July 1. The new requirements are the first of many that health plans will face over the next several years related to the mandatory disclosure of data, as other mandates of both the interoperability rule and the health plan transparency rule are scheduled to take effect in 2022, 2023 and 2024.

Taken together, the interoperability and transparency rules are transforming the data-sharing obligations of health plans. They are part of a quartet of rules issued by the Trump administration that conceive of a world where health care data flows more freely...

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