HHS-OIG’s New Health Information Blocking Rule: Covered Actors; Costly Violations; Federal Interagency Coordination
Priority of Investigations; CMP Assessment; Best Practices for Compliance
Recording of a 90-minute CLE video webinar with Q&A
This CLE webinar will discuss the recently published rule that empowers the Department of Health and Human Services Office of Inspector General (HHS-OIG) to impose civil monetary penalties (CMPs) of up to $1 million per violation for unlawful acts of information blocking beginning Sept. 1, 2023. The panel will describe who is subject to the new rule, OIG's enforcement priorities, interagency cooperation, and how CMPs may be assessed. The panel will also provide key considerations and best practices for compliance.
- Overview of 21st Century Cures Act
- Definition of information blocking
- Information blocking actors
- The final CMP Rule
- Information blocking actors
- Complaint enforcement
- Prioritizing investigations
- Interagency coordination
- Assessing CMPs
- Why healthcare providers should pay attention
- Future rulemaking related to information blocking
- Best practices for compliance
The panel will review these and other important issues:
- Who is subject to the CMP Rule?
- How does the CMP Rule affect healthcare providers?
- What will be the effect of interagency cooperation?
- How can counsel help clients prepare for compliance across their organizations?
- What is the status of ongoing rulemaking related to information blocking?
Carolyn V. Metnick
Ms. Metnick represents a range of healthcare industry clients, including hospitals and health systems, physician... | Read More
Ms. Metnick represents a range of healthcare industry clients, including hospitals and health systems, physician organizations, and digital health companies. She advises on healthcare regulatory and transactional matters with a focus on health information privacy and security. Ms. Metnick advises clients on a range of privacy and security laws, including HIPAA and the California Consumer Privacy Act. She also counsels businesses in data breach investigations and compliance with federal and state breach notification laws. Ms. Metnick is a Certified Information Privacy Professional/United States (CIPP/US) and a Certified Information Privacy Professional/Europe (CIPP/E).Close
Pat G. Ouellette
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo
Mr. Ouellette focuses his practice on representing healthcare organizations and is a Certified Information Privacy... | Read More
Mr. Ouellette focuses his practice on representing healthcare organizations and is a Certified Information Privacy Professional–US (CIPP–US). He advises clients on a broad spectrum of healthcare regulatory, clinical trial, data privacy, PBM, healthcare technology, and transactional matters. Mr. Ouellette has experience drafting and negotiating healthcare services agreements and with technology transactions as well as counseling clients on state licensure rules, compliance with fraud and abuse laws, privacy and data protection issues, and the Interoperability and Information Blocking Rules under the 21st Century Cures Act.Close