Dennis Sapien Pangandian

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184 appearances 1 recordings 1 series first heard Jul 2026 last heard 31 Jul

Dennis Sapien Pangandian’s voice in public audio — every appearance, attributed to the second.

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Recordings per month over the last 12 months — 1 in all, peaking in Jul 2026 with 1.

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AHLA's Speaking of Health Law · Information Blocking Enforcement on the Horizon: Compliance Under the 21st Century Cures Act · 31 Jul 2026 podcast

Are you subject to a civil monetary penalty?

Or are you subject to what's called provider disincentives, right?

So...

Developers, HINs, HIEs, they can be subject to up to a million dollars per violation.

And healthcare providers, though, they can, if they're just a healthcare provider that commits information blocking, the Office of the Inspector General can refer them for what's called provider disincentives.

So they take various forms, right?

They could be penalized by...

being prohibited from participating in an ACO or having your MIPS score affected, things like that.

So it's a little less toothy, but it's really meant to utilize the structures that are already in place to disincentivize information blocking by providers.

I think what's important, though, to note, though, is that if you're a healthcare provider, that doesn't mean you cannot be a developer or an HIN or HIE, and we can talk about that.

Sure.

So it's up to a million dollars.

I think that's the first thing.

Background for me, I used to actually be in the inspector general's office and I worked on these rules.

And I remember when we were considering how to apply these penalties, you could imagine these things either stacking up or if there's a whole range of conduct, then a million bucks could just be a...

you know, the price of the cost of doing business sometimes that people will just factor in.

So depending on how they apply the million dollars per violation can have a significant impact.

Unfortunately, we don't have any examples of enforcement activity, but what we do have is OIG's stated enforcement priorities, right?

What they're going to look at.

And we also have the factors that come into play when they are applying CMPs.

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