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).
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