For EHR vendors, HTI-1 certification deadlines are coming up fast. Here’s your checklist to stay compliant with ONC requirements through 2025 and into 2026:
| Complete by | ||
|---|---|---|
| 1/01/2025 |
Starting January 1, 2025, the decision support interventions certification criterion:
|
|
| 4/15/2025 | Q1 2025 Quarterly Adaptations & Updates Reporting | |
| 4/30/2025 | Semi-annual Attestation Due | |
| 7/15/2025 | Q2 2025 Quarterly Adaptations & Updates Reporting | |
| 08/31/2025 | Certification Deadline for 2026 Real World Testing | |
| 10/15/2025 | Q3 2025 Quarterly Adaptations & Updates Reporting | |
| 10/31/2025 | Semi-Annual Attestations Due | |
| 12/15/2025 | Deadline for 2026 Real World Testing Plan to be made publicly available on CHPL (ACB will require submission at least 30 days prior to the Due Date) | |
| 12/31/2025 |
By December 31, 2025, health IT developers must update and provide to their customers certified health IT that conforms to new and revised standards and certification criteria included in the HTI-1 Final Rule.
See below for details |
|
| 1/15/2026 | Q4 2025 Quarterly Adaptations & Updates Reporting | |
The end-of-year HTI-1 conformance is a heavy lift. Here are some details:
1. USCDIv3 data elements
Your EHR must support new USCDIv3 data elements.
2. FHIR & CCD standards updates
CCDs and FHIR API must be updated to these new standards:
- HL7® SMART App Launch Implementation Guide Release 2.0.0
- HL7 CDA® R2 Implementation Guide: C-CDA Templates for Clinical Notes STU Companion Guide, Release 4.1
- FHIR US Core IG 6.1.0
- FHIR R4.0.1
- Bulk FHIR IG Guide 1.0.1
3. Patient portal data restriction — 170.315 (e)(1)
Patients must be able to restrict sharing of certain classes of data via their patient portal.
4. Public health reporting — 170.315 (f)(5)
Transmission to public health agencies: electronic case reporting will require bi-directional standards-based electronic care reporting via FHIR or CDA eICR.
5. Insight Condition & Maintenance of Certification
You’ll need to begin capturing key metrics such as system performance, clinical impact, risk management strategies, and Predictive Decision Support Interventions (PDSI) utilization to satisfy the Insight Condition and Maintenance of Certification Requirements.
*** Stay tuned for our next blog for more details!
And for vendors working on the Patient Demographics requirements for certification, there are changes stemming from Executive Order 14168 signed January 20, 2025 and published in the Federal Register on January 30th: “Defending Women From Gender Ideology Extremism and Restoring Biological Truth to the Federal Government”. These changes apply directly to § 170.315 (a)(5) Patient demographics and observations but affect all criteria that include sending and receiving patient data. So, Certified Health IT modules are no longer required to record:
- Sexual orientation
- Gender identity
- Sex parameters for clinical use
- Name to use, or
- Pronouns
Contact us for additional information or to schedule a meeting. We are here to help.
