decisionhealth Newsletters, Coder Pink Sheets - 2026 Issue 3 (March)
HHS issues warnings on info blocking; make sure you’re ready
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Article Overview
This article explains the federal government’s growing focus on enforcing information blocking requirements under the 21st Century Cures Act and related ONC/HHS guidance. It is aimed at providers, health IT developers, compliance teams, HIM professionals, and legal or operational leaders who need to understand the current enforcement climate, exception categories, and governance considerations tied to access to electronic health information.
Why This Topic Matters
Information blocking enforcement can affect both technology vendors and provider organizations, including access workflows, portal configurations, exception documentation, and federal program consequences. The article matters because it highlights why organizations should assess internal practices now to reduce compliance risk before enforcement intensifies.
Article Sections
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Federal enforcement outlook
Overview of the federal government’s recent signals about stronger enforcement activity and the agencies involved. Discusses the broader policy context for information blocking oversight.
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How the rules and disincentives developed
Background on the legal and regulatory framework that established information blocking expectations and the later rulemaking around provider disincentives. Covers the general compliance environment without detailing specific operational steps.
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Developers under closer scrutiny
Focus on health IT developers and related entities, including recent agency actions and potential enforcement attention. Explains why developers are a primary target in the current phase of enforcement.
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Why providers still need to pay attention
Discussion of how information blocking concepts may still affect provider organizations even when the immediate enforcement focus is elsewhere. Addresses general risk areas and accountability concerns.
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Exception categories and documentation considerations
High-level review of the exception framework and the importance of documenting the basis for relying on an exception. Describes broad compliance themes related to privacy, security, infeasibility, and other categories.
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Operational readiness and governance
Covers practical planning themes such as anticipating requests, managing portal and app-related issues, and coordinating across departments. Emphasizes governance and cross-functional preparation.
What You Will Learn
- How HHS and ONC are approaching information blocking enforcement
- Which organizations are most directly affected by current enforcement activity
- What broad exception categories are discussed in federal guidance
- Why documentation and internal governance matter for access-related compliance
- How portal and third-party access issues can create compliance risk
Who Should Read This
- Health care providers
- Health IT developers
- Compliance officers
- Health information management professionals
- Health system legal teams
- Operations leaders
- Privacy and security teams
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