WHIMA PAL team submitted a response letter to ONC’s 21st Century Cures Act: Establishment of Disincentives for Health Care Providers That Have Committed Information Blocking proposed rule as published in the Federal Register on November 1, 2023. The proposed rules have significant financial ramifications for providers, negatively impacting incentive payments for ACO, MIPS, and MSSP, as well as a lack of clarity on potential duplication of penalties from multiple agencies, appeals processes, and more.

