News & Analysis as of

21st Century Cures Act Health Information Technologies

Husch Blackwell LLP

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

Husch Blackwell LLP on

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

Epstein Becker & Green

Diagnostic Imaging Interoperability Request for Information Shines a Spotlight on the Lack of Patient-Centered Longitudinal Health...

Epstein Becker & Green on

On January 29, 2026, the Assistant Secretary for Technology Policy/Office of the National Coordinator for Health Information Technology (“ASTP/ONC”) released the Draft United States Core Data for Interoperability Version 7...more

Alston & Bird

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

Alston & Bird on

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

Holland & Knight LLP

The Wait Is Over: Information Blocking Enforcement Is Officially Here

Holland & Knight LLP on

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

Katten Muchin Rosenman LLP

FDA Clinical Decision Support Software Guidance Refresh : Clearer Rules, Broader Innovation

On January 6, 2026, the FDA issued a Guidance for Industry and Food and Drug Administration Staff regarding Clinical Decision Support (CDS) software. The January 2026 guidance supersedes the previous, and less detailed,...more

DLA Piper

FDA Updates Its Clinical Decision Support And General Wellness Guidances: Key points

DLA Piper on

The United States Food and Drug Administration (FDA) issued revisions this month to its guidance documents "Clinical Decision Support Software" (CDS Guidance) and "General Wellness: Policy for Low Risk Devices" (General...more

McDermott Will & Schulte

ASTP’s HTI-5 relaxes certification criteria while tightening information blocking exceptions

On December 29, 2025, the US Department of Health and Human Services (HHS) Assistant Secretary for Technology Policy/Office of the National Coordinator for Health Information Technology (ASTP) published the Health Data,...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

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

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

McDermott Will & Schulte

ASTP Adopts New Protecting Care Access Exception

On December 17, 2024, the US Department of Health and Human Services (HHS) Assistant Secretary for Technology Policy/Office of the National Coordinator for Health Information Technology (ASTP) published the Health Data,...more

Epstein Becker & Green

As the Window for Comments Closes on ONC/ASTP’s HTI-2 Proposed Rule: What’s in HTI-2 and What Does It Mean for You?

Epstein Becker & Green on

On August 5, 2024, the Office of the National Coordinator for Health Information Technology— now known as the Assistant Secretary for Technology Policy/Office of the National Coordinator for Health IT (“ASTP/ONC”) within the...more

Burr & Forman

Healthcare Provider Disincentives for Information Blocking

Burr & Forman on

On June 31, 2024, the Department of Health and Human Services (“HHS”) published a final rule establishing penalties for healthcare providers who violate the information blocking rules implemented under the 21st Century Cures...more

Nelson Mullins Riley & Scarborough LLP

HHS Rule Targets Health Providers Blocking Patient Info Sharing (RIN 0955-AA05)

Healthcare providers are facing penalties for blocking access to a patient’s electronic health information under a new Biden administration rule. On June 24, the U.S. Department of Health and Human Services (HHS)...more

King & Spalding

HHS Finalizes Disincentives for Healthcare Providers That Have Committed Information Blocking

King & Spalding on

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

Baker Donelson

Information Blocking: Disincentives Established for Health Care Providers

Baker Donelson on

The United States Department of Health and Human Services (HHS) has now established disincentives for certain health care providers if found by the Office of Inspector General (OIG) to have committed information blocking...more

Baker Donelson

Providers Take Note: The Common Agreement Version 2.0 Released

Baker Donelson on

The Office of the National Coordinator for Health Information Technology (ONC) released the anticipated Common Agreement Version 2.0 on April 22, 2024. Since 2016, the ONC has been working to implement the requirements of the...more

McDermott+

Stakeholders Request Changes to Proposed Information Blocking Disincentives for Healthcare Providers

McDermott+ on

The public comments are in! The Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) are now reviewing the 136 comments they received on a proposed...more

Burr & Forman

Proposed Penalties for Information Blocking Violations

Burr & Forman on

On October 30, 2023, the Department of Health and Human Services (HHS) released a proposed rule establishing penalties for healthcare providers who violate the information blocking rules implemented under the 21st Century...more

Epstein Becker & Green

HHS Publishes Proposed “Disincentives Rule” to Prevent Information Blocking by Health Care Providers

Epstein Becker & Green on

The U.S. Department of Health and Human Services (HHS)—through the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC)—recently published a...more

Arnall Golden Gregory LLP

Information Blocking Penalties for Healthcare Providers: HHS Proposed Rule

The U.S. Department of Health and Human Services (“HHS”) on October 30, 2023, issued a Notice of Proposed Rulemaking (“NPRM”) to establish penalties for healthcare providers found to have committed information blocking. This...more

BCLP

HHS Proposes Rule to Establish Penalties for Committing Information Blocking: What Providers Need to Know

BCLP on

On October 30, 2023, the U.S. Department of Health and Human Services (HHS) released a proposed rule (Proposed Rule) to establish disincentives for healthcare providers that engage in information blocking under the 21st...more

Bass, Berry & Sims PLC

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

Bass, Berry & Sims PLC on

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

Robinson+Cole Health Law Diagnosis

HHS Proposes Disincentives for Providers that Commit Information Blocking

On November 1, 2023, the U.S. Department of Health and Human Services (HHS) published a proposed rule titled “21st Century Cures Act: Establishment of Disincentives for Health Care Providers That Have Committed Information...more

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