Pulse July 5, 2023
At the end of June 2023, the HHS Office for the Inspector General announced the finalization of the first civil monetary penalties for failing to comply with information blocking requirements. The OIG rule has been a relatively long time coming with a fair amount of hopes also being attached to the rule. Will the possibility of enforcement make a difference though? Oftentimes the ability for penalties to be imposed is viewed as a driver of compliance based on the argument that entities will toe the line to avoid being forced to pay a fine to the government.
Determining the accuracy of that argument will be informed quite a bit by the details of the final rule. The OIG provides a...