The EHR vendor community is working aggressively to upgrade systems to support HTI-1 for 2025 and 2026 by implementing USCDIv3 data requirements for C-CDA and FHIR, along with SMART 2.0. If you are an EHR vendor, though, you may also want to familiarize yourself with new ONC “Insights Condition” requirements that kick in starting January 2026.
Most of you are probably familiar with the ONC 170.315(g)(1) and (g)(2) Automated Measure certification requirements. The new requirements are different since the responsibility for reporting falls on the EHR, not the organizations, providers, or hospitals.
We’re talking about the Insights Condition and Maintenance of Certification component of the ONC’s Health IT Certification Program. New requirements aim to enhance transparency and accountability in the health IT marketplace by requiring developers of certified health IT to report on specific measures and metrics. Take a closer look:
Overview
Similar to the Real World testing initiative, the new EHR Reporting requirements reflect ONC’s interest in utilizing required EHR functionality, specifically interoperability and patient access to Electronic Health Information (EHI). EHR developers must report data aggregated at the product level and reporting will be phased in over several years. ONC will roll out measures for data capture and reporting in three yearly cycles, beginning with Year 1 measures captured in 2026 and reported in July of 2027. Reporting is on an annual basis, with the reporting period being one calendar year.
Here is a list of the new measures and deadlines:
| Measure Description | Related ONC Criteria | Data Collection Starts | Reporting Starts |
| Individuals’ Access to EHI Through Certified Health IT | 170.315(e)(1) and (g)(10) | January 1, 2026 | July 1, 2027 |
| C-CDA Problems, Medications, and Allergies Reconciliation and Incorporation Through Certified Health IT | 170.315(b)(2) | January 1, 2027 | July 1, 2028 |
| Applications Supported Through Certified Health IT | 170.315(g)(10) | January 1, 2026 | July 1, 2027 |
| Use of FHIR in Apps Through Certified Health IT | 170.315(g)(10) | January 1, 2026 | July 1, 2027 |
| Use of FHIR Bulk Data Access Through Certified Health IT | 170.315(g)(10) | January 1, 2027 | July 1, 2028 |
| Immunization Administrations Electronically Submitted to Public Health Information Exchange Immunization Information Systems Through Certified Health IT | 170.315(f)(1) | January 1, 2026 | July 1, 2027 |
| Immunization History and Forecasts Through Certified Health IT | 170.315(f)(1) | January 1, 2027 | July 1, 2028 |
Notes:
More Detail on Metrics:
| ONC Measure Description/Criteria | Summary of Reporting Period Metrics |
| Individuals’ Access to EHI Through Certified Health IT ==> 170.315(e)(1) and (g)(10) | Report three separate metrics re. individuals accessing their EHI: 1) Those using FHIR API, 2) Those using VDT, and 3) Those using any method. |
C-CDA Problems, Medications, and Allergies Reconciliation and Incorporation Through Certified Health IT ==> 170.315(b)(2) | Includes reporting the number of patient encounters, number of unique C-CDAs obtained, number of C-CDAs “pre-processed” to streamline reconciliation/incorporation, number of C-CDAs bypassing reconciliation due to being duplicates or containing no new information and number of C-CDAs actually incorporated. |
Applications Supported Through Certified Health IT ==> 170.315(g)(10) | Name of application, intended purpose and users, and whether application was actually used during the reporting period. |
Use of FHIR in Apps Through Certified Health IT ==> 170.315(g)(10) | Number of distinct EHR deployments and, out of that number, how many retrieved at least one FHIR Resource. Number of distinct certified health IT deployments (across clients) associated with at least one FHIR resource returned by US Core Implementation Guide version |
Use of FHIR Bulk Data Access Through Certified Health IT ==> 170.315(g)(10) | Number of bulk data access requests completed (across clients) to export patient data and number of client implementations that performed at least one bulk FHIR export. |
| Immunization Administrations Electronically Submitted to Public Health Information Exchange Immunization Information Systems Through Certified Health IT ==> 170.315(f)(1) | Number of immunizations performed and then broken out by those successfully and unsucessfully submitted to registries. Also, the number broken out by age group and then totals for each individual registry (ONC calls a registry an IIS — Immunization Information System). |
Immunization History and Forecasts Through Certified Health IT ==> 170.315(f)(1) | Number of immunization queries submitted to IISs and number of queries broken out by success vs. failure. |
Exclusions: Smaller EHR vendors and EHR modules may be excluded, as follows:
How will the data be reported? Well, that’s still a bit mysterious. ONC says: “Health IT developers will submit responses and documentation for the Insights Condition using a web-based form and method. ONC will provide templates that enable submitting the data in a structured, electronic format for this purpose, …”
As always, we are interested in your feedback.
News Flash!
As of April 29th, the Assistant Secretary for Technology Policy (ASTP) (formerly ONC) has announced it will suspend enforcement of all Insights EHR Reporting except Use of FHIR in Apps Through Certified Health IT (bold, italics, above). Click to get details
