USCDI, Bulk Data Exports & EHI Exports: Solid Concepts Requiring Standardization and Maturity

By Hans Buitendijk, Chair, EHR Association Privacy & Consent Task Force

The EHR Association has previously written about our belief that smart deregulation, a core policy priority of the current administration, can eliminate outdated or redundant regulatory requirements that are of limited value to patients, providers, and developers. By focusing on policies that drive improvements in standardized interoperability and health data exchange, regulatory agencies will better support the industry’s ability to deliver safe, effective, and innovative technology solutions without slowing forward momentum or devaluing existing investments.

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EHR Association Statement on the White House “Make Health Tech Great Again” Event and Vendor Pledge

The EHR Association shares the following statement regarding the White House’s “Make Health Tech Great Again” event hosted by CMS and announcing a collaborative effort to “begin laying the foundation for a next-generation digital health ecosystem that will improve patient outcomes, reduce provider burden, and drive value.” 

The EHR Association welcomes the Administration’s innovative thinking on how to accelerate health data interoperability and information sharing and commends the developer community’s proactive commitment to this voluntary pledge. By expanding access pathways—from patient-facing applications to provider EHRs to payer claims management systems—and encouraging adoption of advanced AI and digital tools, the ‘Make Health Tech Great Again” initiative promises to accelerate progress toward a more connected and transparent healthcare ecosystem. We look forward to working alongside CMS, ASTP/ONC, and other stakeholders to learn more about implementing this important initiative.

– Leigh Burchell of Altera Digital Health, Chair of the EHR Association

EHR Association Statement on the AI Action Plan

The EHR Association shares the following statement regarding the Trump Administration’s “Winning the Race: America’s AI Action Plan,” which was released yesterday (July 23, 2025) by the White House. 

“The EHR Association commends the administration for its commitment to advancing safe, effective, and innovative AI. As we evaluate the implications of the AI Action Plan for our member companies, their healthcare provider clients, and, most importantly, patients, we reiterate our call for a uniform, risk-based regulatory model at the federal level. Fragmented state mandates risk slowing innovation and complicating compliance, which could deter innovation and adoption. We look forward to collaborating with regulatory agencies and impacted stakeholders to determine the best path forward in achieving the goals of the AI Action Plan.”

– Leigh Burchell of Altera Digital Health, Chair of the EHR Association

HIPAA Security Rule Part Three: Risk-Based and Industry-Aligned Approaches Recommended

By the EHR Association Privacy & Security Workgroup

This three-part blog series shares the EHR Association’s stance on OCR’s proposed changes to the HIPAA Security Rule. Part one focused on our overarching concerns and issues with proposed definitions. Part two and this installment highlight our concerns with OCR’s proposed expectations. 

The HIPAA Security Rule is overdue for modernization, given the rapid pace of technological change and increasing cybersecurity threats. While we support OCR’s intent to strengthen protections for electronic protected health information (ePHI), our analysis of the HIPAA Security Rule to Strengthen the Cybersecurity of Electronic Protected Health Information raised concerns and questions we hope will be addressed before finalization.

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EHR Association Statement on HTI-2 Final Rule

Following is the statement from the EHR Association on the Dec. 11, 2024 publication by ASTP/ONC of the Health Data, Technology, and Interoperability: Trusted Exchange Framework and Common Agreement (HTI-2) Final Rule, which will publish in the Federal Register on Dec. 16, 2024. The scaled-based rule finalizes certain proposals related to the Trusted Exchange Framework and Common Agreement (TEFCA). It also amends the information blocking regulations by including definitions related to the TEFCA Manner Exception and implements provisions to support the reliability, privacy, security, and trust within TEFCA.

“This first rule finalizing parts of the HTI-2 proposals was released on December 11, 2024, and the focus on TEFCA allows ASTP to solidify pillars of that program that outgoing leadership wants to leave as a legacy. We expect the remaining components of the HTI-2 proposed rule to be split into multiple other final rules. In doing so, the EHR Association hopes that ASTP/ONC will prioritize the necessary additional technical corrections specific to health IT vendors, the most urgent of which relate to Insights Measures. As currently drafted, the Insights Measures are likely to produce data of questionable value – something we have been stressing to ASTP since publication of the HTI-1 proposed rule in 2023. As we inch closer to the January 1, 2026, start date, the uncertainty of finalized measurements creates challenges. We hope that future rules finalizing HTI-2 proposals will include helpful and necessary clarifications.”

HTI-2: Immature Standards and Lopsided Mandates

By Danielle Friend (Epic), Chair, Standards & Interoperability Workgroup, and John Stamm (Epic), Vice Chair, Public Health Workgroup

Previous installments of this 3-part blog series on the EHR Association’s top concerns with HTI-2 focused on the overarching issues and specific issues with the complex web of proposed changes to Insights Measures. Our full comments to ASTP are available on our website.

Along with unrealistic compliance timeframes and out-of-sync cross-agency requirements, ASTP’s Health Data, Technology, and Interoperability: Patient Engagement, Information Sharing, and Public Health Interoperability (HTI-2) proposed rule creates substantial compliance burdens for providers, the EHR developers that support them, and public health agencies (PHAs) due to the laundry list of premature and/or unnecessary and lopsided requirements.

Three areas where these issues are quite prominent are HTI-2’s proposed requirements pertaining to standards, electronic prior authorization (ePA), and public health reporting.

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