Lexology November 28, 2017
Centers for Medicare & Medicaid Services (CMS) recently published two important guidance statements on so-called “information blocking,” i.e., knowingly and willfully limiting or restricting the compatibility or interoperability of certified electronic health record (EHR) technology.1
The first statement is entitled The Merit-Based Incentive Payment System (MIPS) Advancing Care Information Prevention of Information Blocking Attestation: Making Sure EHR Information is Shared (the “MIPS Guidance”), and the second statement is entitled The Medicare and Medicaid EHR Incentive Programs Prevention of Information Blocking Attestation Fact Sheet (the “EHR Fact Sheet”). These guidance statements will be collectively referred to as the “Fact Sheets.” Links to both Facts Sheets are found at the end of this alert.
Who is Subject to the Fact Sheets?
The...
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