News & Analysis as of

21st Century Cures Act Enforcement Actions

Husch Blackwell LLP

HHS Crackdown on Information Blocking: New Era of Enforcement, Fines, and Compliance Risks for Healthcare Entities

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HHS Ramps Up Enforcement Against Information Blocking- 2025 marks a significant turning point in federal enforcement against “information blocking” in healthcare. In a series of announcements this September, the U.S....more

Alston & Bird

Information Blocking Enforcement Enters a New Phase: What Digital Health Stakeholders Should Expect in 2026

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Our Health Care Group reviews recent developments signaling a shift toward more active enforcement of the 21st Century Cures Act’s information blocking requirements and what digital health entities should expect in 2026....more

Husch Blackwell LLP

Enforcement Ramps Up on Patient Right of Access: What Providers Need to Know 

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The Health Insurance Portability and Accountability Act (HIPAA) has long been the cornerstone of patient privacy and data protection. Among its most patient-centric provisions is the Right of Access rule, which guarantees...more

Holland & Knight LLP

The Wait Is Over: Information Blocking Enforcement Is Officially Here

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We were told it would arrive, heard it was on the brink, and now it is here. In the opening session of the U.S. Department of Health and Human Services (HHS) Assistant Secretary for Technology Policy (ASTP) 2026 Annual...more

Morgan Lewis - As Prescribed

New Year, New Guidance: FDA Revisits Wellness and CDS Boundaries

The FDA released updates to two guidance documents on January 6: General Wellness: Policy for Low Risk Devices (General Wellness) and Clinical Decision Support Software (CDS). FDA did not issue a traditional press release;...more

Cooley LLP

FDA Opens Aperture for Wearables in Latest General Wellness Guidance

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On January 6, 2026, the US Food and Drug Administration (FDA) issued two revised guidance documents relating to general wellness products (General Wellness Guidance) and clinical decision support software (CDS Software...more

Rivkin Radler LLP

Electronic Visit Verification (EVV): The New Frontier in Home Health Fraud Enforcement

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The 21st Century Cures Act (“Cures Act”) required states to adopt electronic visit verification (EVV) systems for Medicaid-covered personal care services (“PCS”) by January 1, 2020 and for home health care services (“HHCS”)...more

Akerman LLP - Health Law Rx

HHS Announces Increased Efforts to Curb Information Blocking Practices

In a September 3 Press Release, the U.S. Department of Health and Human Services (HHS) announced that it is increasing efforts to curb information blocking. This was quickly followed by a September 4 Enforcement Alert issued...more

ArentFox Schiff

HHS Signals Heightened Information Blocking Enforcement

ArentFox Schiff on

Federal enforcement of information blocking rules has entered a new era. On September 3, the US Department of Health and Human Services (HHS) issued a press release announcing a “crackdown” on the “harmful practice” of...more

DLA Piper

HHS Steps Up Enforcement on Health Information Blocking

DLA Piper on

The US Department of Health and Human Services (HHS) announced, on September 3, 2025, a major enforcement initiative targeting “information blocking” – the practice of restricting access, exchange, or use of electronic health...more

Wilson Sonsini Goodrich & Rosati

HHS Announces Increased Resources to Enforce Information Blocking Prohibition

On September 3, 2025, the U.S. Department of Health and Human Services (HHS) announced that HHS would increase resources to enforce the information blocking prohibition under the 21st Century Cures Act. Generally, the...more

Gardner Law

Whoop vs. FDA

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In FDA regulatory matters, companies must carefully choose when to challenge the government, and when to comply. In a recent case, Whoop, the Boston-based wearable maker, has chosen to openly challenge the U.S. Food and Drug...more

McDermott Will & Schulte

HHS announces information blocking enforcement “crackdown”

The US Department of Health and Human Services (HHS) announced its intent to begin actively enforcing the information blocking regulations adopted under the 21st Century Cures Act, in a press release on September 3, 2025, and...more

Orrick, Herrington & Sutcliffe LLP

Will FDA’s Warning Letter to WHOOP Put a Chill on Wearables?

FDA’s Warning Letter to WHOOP, a manufacturer of cutting-edge, wellness wearable tech, has sent shivers through an industry enjoying exponential growth in the health and wellness space. “Wellness technology”, a result of the...more

King & Spalding

HHS Finalizes Disincentives for Healthcare Providers That Have Committed Information Blocking

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Last week, HHS published its final rule outlining disincentives for certain healthcare providers that have committed information blocking (the Final Rule). The Final Rule also provides information related to OIG’s...more

Health Care Compliance Association (HCCA)

[Event] Healthcare Privacy Compliance Academy - May 6th - 9th, San Antonio, TX

Ideal for professionals with some compliance knowledge and experience, HCCA’s Healthcare Privacy Compliance Academy offers practitioners a deeper understanding of effective compliance management in a healthcare setting. The...more

Bass, Berry & Sims PLC

HHS Proposes Rule to Establish Disincentives for Healthcare Providers That Engage in Information Blocking

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In 2020, when the U.S. Department of Health and Human Services (HHS) published its Final Rule to implement the information blocking prohibitions of the 21st Century Cures Act, HHS left healthcare providers wondering what...more

Health Care Compliance Association (HCCA)

[Event] Healthcare Privacy Compliance Academy - October 16th - 19th, San Francisco, CA

Designed for professionals with some compliance knowledge and experience, HCCA’s Healthcare Privacy Compliance Academy is ideal for practitioners who want a deeper understanding of effective compliance management in a...more

McDermott Will & Schulte

[Webinar] How Not to Lose $1M: Preparing for HHS-OIG Info Blocking Enforcement - August 15th, 1:00 pm - 2:00 pm EDT

The US Department of Health and Human Services Office of Inspector General (HHS-OIG) issued a final rule to implement its authority under the 21st Century Cures Act to investigate allegations of information blocking and...more

McDermott Will & Schulte

Special Report - A Million Reasons to Share: OIG’s Final Rule on Information Blocking Enforcement

On July 3, 2023, the US Department of Health and Human Services Office of Inspector General (OIG) published its long-awaited final rule implementing the 21st Century Cures Act provisions authorizing OIG to investigate claims...more

Health Care Compliance Association (HCCA)

[Virtual Event] Columbus & Indianapolis Regional Healthcare Compliance Conference - June 2nd, 8:25 am - 4:30 pm ET

General and specialty compliance education from the comfort of your home or office - HCCA’s Regional Healthcare Compliance Conferences provide practitioners with virtual compliance learning that covers a wide variety of...more

Health Care Compliance Association (HCCA)

[Event] Regional Healthcare Compliance Conference - January 20th, Atlanta, GA

Looking for compliance education and networking in your area? HCCA’s Regional Healthcare Compliance Conferences offer practitioners convenient, local compliance education, including updates on the latest news in regulatory...more

Health Care Compliance Association (HCCA)

[Virtual Event] San Francisco Regional Healthcare Compliance Conference - December 2nd, 8:25 am - 4:30 pm PST

General and specialty compliance training from the comfort of your home or office! HCCA’s Regional Healthcare Compliance Conferences provide practitioners with virtual compliance training that includes updates on the...more

Health Care Compliance Association (HCCA)

[Event] Regional Healthcare Compliance Conference - October 28th, Louisville, KY

Looking for compliance training and networking in your area? HCCA’s Regional Healthcare Compliance Conferences offer practitioners convenient, local compliance training, including updates on the latest news in regulatory...more

Health Care Compliance Association (HCCA)

[Event] Research Compliance Conference - June 8th - 10th, Anaheim, CA

Hear about the latest in research compliance - Do you want to learn… - How to prepare for upcoming changes in Medicaid? - Ways to build and maintain a better research compliance work plan for your program? - How...more

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