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Understanding the Information Blocking Rules


Gain a better understanding of the Information Blocking Rule and tips for compliance.

The Information Blocking Rule, which was promulgated by the Department of Health and Human Services under the 21st Cures Act, is one of the most significant developments in health care regulation since the passage of the Health Insurance Portability and Accountability Act of 1996. By promoting health information liquidity, the rule lays the foundation for a mobile health application ecosystem that will finally allow individuals in the U.S. to access and aggregate their health information as easily as they use banking apps to access their financial information. This program will explain the objectives of the Information Blocking Rule and define what constitutes prohibited information blocking. It will also address what information must be provided to patients and the narrow exceptions to the rule. Additionally, we will discuss the very significant penalties for violations by certified technology developers and disincentives that may be imposed on health care providers. Attendees will leave the program with a practical understanding of the Information Blocking Rule and tips for compliance that they can apply to their operations.



Anna L. Spencer

Anna L. Spencer

DLA Piper

  • Partner in DLA Piper
  • Primarily focuses on matters involving the privacy, security, and electronic exchange of health information and is the HIPAA privacy officer for the firm
  • Has more than twenty years of experience assisting companies craft practical solutions to complex regulatory, public policy, and enforcement matters
  • Regularly counsels companies on compliance with HIPAA, HITECH, state confidentiality requirements, Part 2 protections for substance abuse treatment records, GINA, privacy and security rules promulgated by the Centers for Medicare & Medicaid Services (CMS), the Food and Drug Administration’s cybersecurity guidance for medical device companies, and privacy requirements under the Common Rule
  • Investigates and responds to data breaches and information security incidents and defends covered entities and business associates in investigations by the Office for Civil Rights, US Department of Health and Human Services (OCR)
  • Co-authored a treatise on health information privacy and security for Bloomberg Law
  • J.D. degree, Vanderbilt University Law School; B.A. degree, magna cum laude, Phi Beta Kappa, Sewanee
  • Can be reached at [email protected]

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