Are you ready for IBR enforcement? In the latest Coppersmith Brief, Mel Soliz and Ben Yeager lay out the information blocking enforcement landscape for health care providers under the Proposed HHS Disincentives Rule and for health IT developers and HIN/HIEs under the Final OIG CMP Rule 

The Brief outlines two key rule changes: 

  1. The Office of the Inspector General finalized the OIG CMP Rule & began enforcement against health IT developers and health information networks/exchanges. Those who have committed information blocking face penalties up to $1 million per violation.
  2. The new HHS Disincentives regulation proposal outlines penalties for healthcare providers who have committed information blocking. If participating in certain Medicare programs, providers could face disincentives. 
    • Those not participating have delayed enforcement pending further rule making. Stakeholders interested in commenting on the Proposed HHS Disincentives Rule must submit their comments no later than January 2, 2024. 

The detailed Brief puts the current state of IBR enforcement into context for health care providers, health IT developers and HIN/HIEs and provides practical tips for how to prepare for IBR enforcement through implementation of an IBR compliance program. 

Click here to read the full IBR Brief. 

Discover more Coppersmith Briefs here.