Benefit — Disclosure stance
What the disclosure-obligation clock actually costs to miss
Cures Act information-blocking + ONC HTI-1 DSI transparency created independent civil-monetary-penalty pathways. Undisclosed known drift is a distinct enforcement matter separate from the underlying performance issue.
The three enforcement pathways
- OIG information-blocking CMP. Up to $1M per violation for actors including hospitals. Determination based on knowledge + interference + reasonableness.
- ONC certified-health-IT decertification chain. If the certified DSI is decertified, the hospital may lose Meaningful Use / Promoting Interoperability eligibility — direct Medicare payment adjustment.
- Medicare Promoting Interoperability Program penalty. Failure to attest to appropriate use of certified DSI = 1% Medicare payment adjustment (compounding for multi-year non-attestation).
The specific "knowledge" question
OIG's information-blocking analysis turns on "knew or should have known." Once the Snapshot lands, hospital "should have known" starts running as of the report date. The disclosure + escalation clock begins. Silence is the risk.
Documented escalation. The 3 fix-first items in the Snapshot include recommended escalation targets. Following them — and documenting the escalation — removes information-blocking as a live risk on this specific finding.
Dollar frame
OIG CMP per violation: up to $1M per act of information blocking.
Medicare payment adjustment: 1% per year of non-attestation, compounding. Material for large-Medicare-population hospitals.
Certified DSI decertification: operationally disruptive; may require workflow re-implementation.
Who at your org cares
- Chief Information Officer / Chief Medical Information Officer — certified-health-IT stance
- Chief Compliance Officer — disclosure workflow
- General Counsel — OIG CMP defense
- Chief Financial Officer — Medicare payment adjustment exposure
- Medical Staff Governance — clinician-notification workflow
What "having it" looks like
Green: Snapshot triggers escalation workflow. Affected clinicians notified. Certified-DSI vendor informed. Documentation trail preserved. Information-blocking risk closed on this finding.
Red: Snapshot filed silently. Drift becomes known internally but not disclosed to affected clinicians or follow-on systems. OIG's "knew and interfered" element is now live.
$499. 3 business days.
The document that starts the disclosure clock cleanly — with a defensible timeline + recommended escalation targets.
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