In other installments of this five-part blog series on the EHR Association’s issues with ONC’s Health Data, Technology, and Interoperability: Certification Program Updates, Algorithm Transparency, and Information Sharing Proposed Rule (HTI-1), we discussed our overarching concerns, as well as specifics concerns with Insights Condition, the proposed requirements related to Decision Support Interventions (DSI) and Predictive Models, and Patient Requested Restrictions. In this installment, we examine issues with provisions related to the transition to USCDI v3.

More Time, Flexibility Needed

While we strongly support ONC’s efforts to advance USCDI in general, the proposed Jan. 1, 2025, development and implementation timeframe between the final rule and USCDI v1 expiration is far too short. It also needs to align with CMS timelines. Thus, we would like to see the deadline for USCDI v3 to be included in upgraded versions moved to the end of the second calendar year following the publication of the final rule (estimated to be Dec. 31, 2025). 

We also reiterate our desire to see ONC move away from the current all-or-nothing certification requirement and towards a dynamic approach based on the data actually managed by the EHR or other health IT in use by a provider. 

Specialty EHRs and provider organizations that don’t benefit from supporting all USCDI criteria – e.g., geriatric-focused health IT that has no clinical need to support pediatric data, or diagnostic and imaging services that seek software that is relevant to “their” data but nothing unnecessary – should be allowed to achieve certification by adding only those aspects beneficial to meet user needs. Adopting the more flexible model would alleviate unnecessary burdens for both health IT vendors and those providers to whom the broader USCDI data list is not applicable. 

You can read more about this recommendation in The rationale for changing the ‘all or nothing’ approach to USCDI certification on Healthcare Data Management. 

Multiple Concerns

Other blogs in this series delve into our concerns with three additional provisions of HTI-1: the Insights Condition program, proposed requirements related to DSI and Predictive Models, and Patient Requested Restrictions. 

Our hope is that ONC gives full consideration to our concerns – which we share with other impacted stakeholders – as it moves forward with finalizing the rule. Doing so would ensure its end goals can be achieved without unrealistic deadlines and without placing an undue burden on healthcare providers and health IT developers.