By Stephanie Jamison (Greenway Health), Chair, and Leigh Burchell (Altera Digital Health), Vice Chair, EHR Association Executive Committee
In the months leading up to ASTP’s July 2024 release of the Health Data, Technology, and Interoperability: Patient Engagement, Information Sharing, and Public Health Interoperability (HTI-2) proposed rule, the EHR Association and other health IT stakeholder organizations braced themselves for what was certain to be a massive policy proposal. Those fears were quickly realized when the overwhelming scope of proposed new and expanded software requirements in the 1067-page HTI-2 NPRM was revealed.
Following our in-depth analysis of HTI-2 and the process of drafting comments, the Association has identified concerns related to public health, standards, Insights measures, and electronic prior authorization requirements within the proposed rule, all of which will be discussed in greater detail in the subsequent blogs in this HTI-2 series. Additionally, there are several overarching issues we believe need to be addressed – including some previously raised by the EHR Association that have yet to be adequately addressed by ASTP and other regulatory agencies.
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