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New final rule from ASTP: ✅ Streamlined prior authorization via FHIR ✅ Real-time drug costs at the point of care ✅ Updated eRx standards Less red tape. Faster access. Better outcomes. #HealthIT #FHIR https://t.co/DWvLao6enm

So we have the #ASTP #ONC HTI-2 FR out! BUT, it is really just part of the proposed rule. HTI-2 FR deals with the TEFCA proposals and a few other administrative changes. The rest (USCDI v3, expanded API, public health, etc.) will come in later HTI-? rule.

And of course today CMS also released their NPRM on PFS which has updates on MIPS 2025 proposals among other things. I guess I'm just happy they dropped these both today instead of last week before the 4th.

The proposed regulation text section itself is 200 pages long. That is basically the same size as the original 2011 Edition Final Rule, including comments/responses all put together. This is a big document.

Another comment on HTI-2's complexity. NPRM is over 1000 pages of PDF double space format ONC uses. That is basically the same size as a FR which typically double from their NPRM size because of all comments/responses in the preamble. HTI-2 FR will likely be close to 2000 pages.

I’ve obviously just quickly perused this and need more time, but proposed HTI-2 is far more complex than HTI-1. HTI-1 was mostly extending functionality from previous #ONC Cures and Edtions rules. HTI-2 is branching out in new areas and in new ways.

They waited until the last minute, but #ONC got the HTI-1 FR out before the annual meeting.

Food for thought, but we will see what ONC ultimately does. Have a great Thanksgiving!

Also, it would help the ACBs not to have to do all their compliance checking at the end of the year and working around holidays. Oct 1 deadline is much easier to support, and it actually aligns with the government’s fiscal year so that could help too.

This means developers are always implementing and updating to the new USCDI, but by making it predictable on a regular cycle, companies can plan on this and make the process more efficient.

Then in 2026, with USCDI v5 IGs ready for implementation, we sunset USCDI v3 and its IGs and make v4 (and its IGs) the minimal with v5 now as optional in SVAP. Since we will also get USCDI v6, HL7 can start on its new IGs and have them ready for next year.

Instead, USCDI v3 and IGs would be established as the minimum standard required by July or October 2025 with USCDI v1 (and its IGs) rolling off certification program. Around the same time, USCDI v4 IGs will be ready and can be added as optional via SVAP certification program.

ONC finalizes their new version of USCDI in June, so the cycle is based on that. Next year, we will get USCDI v5, but we won't be ready to implement it as its respective IGs still need to be created.

I would recommend ONC move to the expected process of updating to the new version of USCDI every year around July or October for Maintenance of Certification compliance. The pattern would go like this.

However, long term, I think 7/1/2025 or even 10/1/2025 puts them in a position to then start a regular and predicable cadence of updating USCDI and its IGs each year while sunsetting older versions of USCDI.

For the short term, developers need 18 months to get this done. Most developers are now at least looking at USCDI v3, but they have not started work in earnest because they are justifiably looking to see what the regulation requires of them first.

My suggestion is to add another 6 or 9 months and make it either 7/1/2025 or 10/1/2025. I think this is best for both short term and long term direction of the program.

Most of the proposals in HTI-1 had expected compliance deadlines of 1/1/2025. This includes the update to USCDI v3 and the CCDA and FHIR IGs that support it. Given both ONC's precedent with rules I think they will extend these deadlines.

Obviously we won't have the #ONC HTI-1 FR by Thanksgiving. They still have an EO12866 meeting scheduled for 11/28 so that puts it around Dec 1st at the earliest. What does that do with the expected deadline dates? We will see, but here is what I think they should do.