How Healthcare Organizations Can Avoid HHS Penalties With Muspell Archive

On September 3, 2025, the U.S. Department of Health and Human Services (HHS) announced a major crackdown on health data blocking under the 21st Century Cures Act. For the first time, healthcare providers, EHR vendors, and Health Information Networks (HINs/HIEs) will face strict penalties for hindering patient data access.

This announcement builds on rules finalized in June 2024, when HHS established provider disincentives for information blocking. But now, enforcement is no longer theoretical - it’s real, with investigations and fines underway.

Why does this matter? Because information blocking isn’t just a compliance issue - it’s a patient rights issue. Patients deserve timely, transparent access to their medical records. Organizations that fail to provide this access risk fines, investigations, and the erosion of patient trust.

Healthcare leaders can no longer afford to leave data locked inside outdated systems. The time to act is now.

Explore:
1. What Is Information Blocking?
2. What HHS Is Doing About It?
3. The Legacy System Problem
4. How Muspell Archive Helps Healthcare Organizations Stay Compliant
5. The Bigger Picture: Empowering Patients & Innovators

1. What Is Information Blocking?

At its core, information blocking happens when someone makes it unnecessarily difficult to access or share Electronic Health Information (EHI).

1.1. Examples of Information Blocking

• Outdated EHRs that don’t integrate: Hospitals still running legacy EHRs that cannot connect with modern platforms, effectively isolating historical patient data
• Excessive vendor fees: Providers often face high charges when trying to extract records from systems like Cerner and other EMRs
• Patient access hurdles: Patients are often forced to navigate delays and technical barriers to obtain their own health records
• EHI export loopholes: While the Cures Act requires complete dataset exports, some vendors complicate or restrict the process to slow access

The 21st Century Cures Act (2016) established that patients and providers should have full, straightforward access to health data - without financial or technical barriers.
 

2. What HHS Is Doing About It

HHS is moving from policy guidance to real enforcement action. According to a September 2025 press release, the department will:

• Investigate complaints of information blocking
• A guide to help organizations comply
• Impose penalties on violators, including providers, EHR vendors, Health IT developers, and Health Information Networks (HINs/HIEs)

2.1. What Non-compliance Means

• Up to $1 million per violation for health IT developers and networks
• Provider penalties: CMS and OIG referrals will bring stricter accountability to providers
• Proactive investigations: HHS will audit and review organizations - even if blocking was unintentional

The takeaway? Non-compliance is no longer just risky - it’s costly.

3. The Legacy System Problem

Despite industry-wide adoption of modern EHRs, many healthcare organizations still depend on legacy applications to store historical patient records. These outdated systems create significant challenges:

• Difficult Access: Clinicians often struggle to locate or retrieve older records quickly, leading to delays in patient care
• Siloed Data: Legacy systems typically lack interoperability, leaving valuable clinical and financial information trapped in isolated databases
• High Costs: Maintaining these aging platforms drains IT budgets with licensing, infrastructure, and support costs - resources that could be redirected to innovation
• Compliance Risks: When older systems can’t deliver patient data in the standardized formats mandated by HHS, organizations face exposure to penalties, even if the blocking is unintentional

The bottom line: legacy systems don’t just slow down workflows - they increase risk, inflate costs, and hinder compliance in an era of stricter HHS enforcement.

4. How Muspell Archive Helps Healthcare Organizations Stay Compliant

314e’s Muspell Archive is a purpose-built solution to eliminate the risks of legacy systems while enabling full compliance with the 21st Century Cures Act. Modernizing access to historical data ensures that organizations stay audit-ready while empowering clinicians and patients alike.

1. FHIR-native Data Archiving
Built on HL7® FHIR® standards, Muspell Archive ensures seamless data exchange across modern healthcare systems. This interoperability directly addresses HHS requirements and eliminates barriers that could otherwise be flagged as information blocking.

2. 21st Century Cures Act Compliant
Muspell was designed in alignment with the 21st Century Cures Act. It guarantees that patients, providers, and third parties can access health data quickly, transparently, and in standardized formats - keeping organizations compliant with the latest federal rules.

3. Embedded Within Leading EHR Workflows
Clinicians don’t have to leave their day-to-day systems to find old records. Muspell Archive integrates directly into modern EHR platforms - such as Epic, Cerner, and others—making archived records instantly accessible without the disruption of switching applications or portals.

4. Secure, Compliant Access
Patient data security and privacy are built in. With granular role-based access controls, HIPAA and ONC alignment, and full audit trails, Muspell ensures compliant data handling while protecting against unauthorized access.

5. Modern UI & Advanced Search
Hidden information blocking often comes from data being technically available but practically inaccessible. Muspell’s intuitive interface and advanced search tools eliminate that risk by making historical records easy to find, retrieve, and use in seconds.

6. Long-term Data Retention
Both clinical and financial data are retained for legally mandated periods, ensuring organizations remain compliant with retention laws while maintaining full accessibility to historical information.

7. Cloud-native Scalability
As organizational data grows, Muspell Archive scales effortlessly while maintaining performance, compliance, and cost efficiency - future-proofing data archiving strategies.

8. Point-of-care Usability
Archived data isn’t just stored - it’s surfaced where it matters most. Clinicians can view and use historical patient information directly at the point of care, supporting seamless treatment decisions.

9. Disaster Recovery & Continuity
Whether facing system outages, cyber incidents, or EHR migrations, Muspell Archive ensures uninterrupted, compliant access to patient records, safeguarding continuity of care.

10. Cost Savings & Risk Reduction
By decommissioning costly legacy systems, organizations cut unnecessary IT spend, reduce compliance exposure, and redirect resources toward innovation and patient care.

Muspell Archive isn’t just a compliance solution - it’s a bridge between the past and the future of healthcare data, turning archived records into an accessible, secure, and interoperable resource that benefits patients, providers, and innovators alike.

5. The Bigger Picture: Empowering Patients & Innovators

While compliance with HHS rules is essential, the true value of Muspell Archive lies in how it transforms access to healthcare data. By eliminating barriers and unlocking legacy records, it empowers both patients and innovators in ways that go beyond regulatory checkboxes.

5.1. For Patients

Accessible historical data supports better condition management, reduces clinical errors, and ensures care continuity across providers. Patients can also integrate their records with digital health tools and wellness apps, giving them more control over their health journey. 

Real-world use case:
For instance, a cancer patient was able to instantly access five-year-old records within Epic using Muspell Archive. Their hospital had recently decommissioned a legacy oncology system. This access sped up treatment decisions and reduced stress.

5.2. For Clinicians

Seamless access to historical records ensures they can make more informed decisions at the point of care, even when treating complex cases that require years of patient history.

5.3. For Innovators 

With legacy data no longer locked away, startups and health systems can power AI-driven care coordination, predictive analytics, and new digital health solutions that enhance outcomes and efficiency.

Real-world use case:
A digital health startup tests AI-driven care coordination by leveraging radiology records made accessible through Muspell’s FHIR-native design.

Muspell Archive doesn’t just keep organizations compliant - it unlocks the future of patient-centered and data-driven healthcare.

With HHS actively cracking down on information blocking, the stakes for healthcare organizations have never been higher. Legacy systems, data silos, and outdated workflows now carry the risk of million-dollar fines and regulatory action.

Muspell Archive removes these risks by making legacy patient data accessible, searchable, and fully interoperable - right within modern EHR workflows. It ensures compliance, reduces costs, and enables innovation. Experience the power of Muspell Archive firsthand – request a quick demo today and see how it transforms healthcare data management.