Dennis Sapien Pangandian
speaker
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 · last 12 monthsRecordings per month over the last 12 months — 1 in all, peaking in Jul 2026 with 1.
Appearances
What are you?
What are you doing?
What hat are you wearing?
And as a provider, we want them focused on patient care.
But developers, HINs, HIEs who are well-versed in that space, they have a lower burden of proof for the government to prove because they should know better effectively is what Congress is saying.
No.
So...
So the analogy, right?
The government still has the burden of proof of showing a violation is actually occurring.
So you can also get as close as possible to an exception or make a defensible argument, but the government still needs to demonstrate knowledge.
I think that's where you can fall back on.
And so just because you don't fit with an exception, the government still needs to prove an underlying violation first and foremost.
And whether or not the OIG uses its enforcement discretion to go after a case based on the facts at hand, that's going to be up to OIG.
You know, I think every year we've seen HHS put in its budget a request for authority to issue advisory opinions, much like how OIG does, right, to various, you know, kickback-type scenarios.
And I...
To date, they haven't been given that authority.
But if and when they do, I think, again, it's going to be very analogous to AKS and how it's enforced and how we can get guidance as to what we can or cannot do in our practices.
So, yeah, and the only thing that throws off this analogy is they use information blocking exceptions as opposed to safe harbors.
But, you know, but think of it as a safe harbor.
Exactly.
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