The fine for denying patients access to health records was so high in the event mentioned in the article because, in this particular case, the non-cooperation of the Covered Entity contributed to the size of the fine (you can read about the case here). Since this case, the CMS´ Meaningful Use program has evolved into the Promoting Interoperability program, and – in addition to being sanctioned for a HIPAA violation – any covered entity failing to provide health records in a timely manner could now also lose a percentage of their Medicare payments.