Dennis Sapien-Pangindian Gets Published by AHLA on Information Blocking

On February 12, 2026, the American Health Law Association published Dennis Sapien-Pangindian's bulletin, “Information Blocking Enforcement on the Horizon: Compliance Considerations Under the 21st Century Cures Act." In the bulletin, Mr. Sapien-Pangindian examines the rapidly evolving enforcement landscape surrounding the federal information blocking framework. As the U.S. Department of Health and Human Services signals a heightened enforcement posture and private litigants begin invoking information blocking principles in civil disputes, the regulatory risks for health care providers, health IT developers, health information networks, and exchanges continue to expand.

The bulletin covers:

• The statutory and regulatory framework governing information blocking

• HHS-OIG’s investigative priorities and civil monetary penalty authority

• The nine regulatory exceptions to information blocking conduct

• The role of “appropriate disincentives” for providers

• Emerging civil litigation risks beyond government enforcement

• Practical compliance considerations grounded in the Seven Elements of an Effective Compliance Program

The publication reflects Mr. Sapien-Pangindian's continued focus on fraud and abuse enforcement, regulatory risk mitigation, and strategic compliance counseling for health care and health technology organizations.

View the full article on the American Health Law Association website: https://www.americanhealthlaw.org/content-library/publications/briefings/4e306a62-dd7b-449d-b143-b64a163a9c5d/Information-Blocking-Enforcement-on-the-Horizon-Co?Token=41c5b0f8-5b64-4816-aecc-fa29f2074622

Copyright 2026, American Health Law Association, Washington, DC. Reprint permission granted.