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Five ONC Requirements in the HTI-1 Rule with Deadlines

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A Running Start to 2024: Five ONC Requirements in the HTI-1 Rule with Deadlines You Should Know About

The ONC announced the HTI-1 Notice of Proposed Rulemaking back in April 2023, and there is good reason to expect the Final Rule to be issued by the end of 2023. Many of the compliance deadlines are set for 2024.  With potentially a year or less to comply with multiple new rules (summarized below), how can developers prepare for a busy compliance year in 2024?  In short, start planning now, so you can hit the ground running early next year. 

The proposed rule includes 18 new and revised certification criteria across a 600+ page proposal description—it’s daunting. We recommend product developers prioritize understanding the potential impacts the rulemaking will have on their development roadmap, focusing first on the significant deadlines in the first year of the two-year rule change rollout.  Let’s take a look at the near-term requirements…

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Going Beyond Proprietary APIs

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As the need for interoperability grows, so does the necessity for a sustainable and future-proof approach to interoperability.

Most systems or solutions claim to “have our own API” or APIs to connect or communicate with other systems. And some of them also have their “interface teams” who help with the plumbing and engineering of their integrations.

While all APIs are not equal (in type and architecture) they are also designed for the most part to suit the needs of the application and business scope and strategy, without complete consideration of the eco-system they must contribute to. This is what makes API customization and management even more necessary (and an overhead) in the attempt to facilitate true interoperability; not to mention that this customization will vary from system to system it wants to integrate with.

Putting integration teams to work or getting interface engines to pick up half the integration throughput is an added burden to solutions that need to implement interoperability in a variety of use cases.

Standardization of the interoperability framework and a future-proof approach to managing data and workflow across platforms and systems has taken the pain out of the management and customization of APIs and integrations and significantly reduced the “interface team” overhead.

Sustainability and repeatability across a variety of integration needs can be achieved with an intelligent interoperability platform that adopts a standards-based approach.

– Aditya Ayyagari, CTO Carefluence

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You have your G 10 Certification. Now what?

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EHR vendors took on the challenge and obtained their certification from the Office of the National Coordinator (ONC) for G 10 criteria. Whether they implemented an integrated solution or licensed a standalone third-party FHIR® server for their customers, they checked the compliance box for a “Standardized API for patient and population services”.

In keeping with the spirit and purpose of the rule, checking the compliance box is not enough. Achieving interoperability is the overarching goal.

Under the API Maintenance of Certification requirement, the health IT developer needs to demonstrate and put to real world use the “standardized API”. With the solution they have implemented their EHR needs to be capable of true interoperability.

Also, the health IT developer should go further and ensure that none of its actions constitute information blocking or impede the suitable access and exchange of electronic health information.

A SMART platform like Carefluence® holds out the promise and demonstrated capability for true interoperability, while satisfying the need of ONC compliance as well.

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Cures Act EHR Compliance: Time is Running Out

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Complying with the 21st Century Cures Act requirement to demonstrate that an electronic health record is able to securely share data with patients and other providers –known as the G(10) Standardized API for Patient and Population Services – should be job 1 for vendors and providers.

The Dec. 31 deadline for EHR vendors to have tested and received certification through an ONC- authorized authority (or a date set for certification) is just days away. Varying penalties, including fines, will apply thereafter. A significant number of the nation’s EHRs are yet to be listed on the Certified Health IT Product List as having complied with the G (10) requirement.
The testing bodies are overwhelmed. Failure to comply leads to financial penalties. Hospitals and physician offices may not be aware of this, but they could lose Medicare revenue for failing to have a compliant EHR.

There is some good news though: EHR vendors can achieve compliance through third party sources. It all boils down to available resources versus the amount of time left before the deadline.

There is the option for testing and certifying electronic health record software to show that it meets the criteria of at minimum a “base” system. At a minimum, the EHR must::

  • Include all patient demographic and clinical health information
  • Provide clinical decision support
  • Support physician order entry
  • Capture and query information relevant to healthcare quality
  • Be able to exchange electronic health information with, and integrate such information from other sources

If EHR vendors do not have the time, or they cannot get a testing date, they can license a system such as Carefluence’s, and without integrating or testing offer it to their customers in order to fulfill the need of a
base electronic health record.

Our plug-and-play solution utilizes our FHIR ® R4 server and includes a built-in transformer for data normalization, providing you with connectivity to any health information system, EHR, patient portal, lab or other system without requiring point-to-point interfaces.

Carefluence understands that each of our clients has a unique business model, so we tailor our installation to your needs. Our technical team will be involved in the certification process at every stage until G(10) compliance is achieved.

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