Info blocking ‘disincentives’ rule brings penalties; data-sharing adjustments needed

Why This Topic Matters

Providers and health care entities need to understand how the final rule may affect Medicare participation, performance-based payment programs, and shared savings arrangements, as well as how privacy obligations and internal workflows interact with federal information-sharing requirements.

Article Sections

1. Agencies continue to sharpen scope

   Summarizes the federal background leading up to the final rule, including the evolution of information blocking policy and the programs affected by the new framework. It also identifies the agencies involved and the general categories of disincentives described.

2. Ask yourself: Are you blocking?

   Discusses the compliance tension between information access expectations and privacy or security obligations. It also covers general categories of sensitive information and related concerns raised by providers and legal counsel.

3. Exceptions move the rule

   Reviews the role of ONC exceptions, the standard described in the article, and the need to document reliance on an exception. It also touches on the practical importance of internal review and staff awareness.

4. Other steps to take

   Describes broader compliance measures such as vendor contract updates, staff training, and internal auditing. The section emphasizes organizational preparation and ongoing monitoring.