HTI-1 in 2027 and What Your Practice Should Check in Its EHR

HTI-1 is no longer a future EHR update. Its certification deadlines have passed, and the last grace period for developers closed on February 28, 2026 – extended from the original January 1, 2026 date after the October-November 2025 government shutdown disrupted ONC’s testing tools and developer support. For a medical practice, the useful question now is whether your EHR vendor delivered the updates that apply to your system and whether those capabilities hold up in your real clinical and administrative workflows.

For a medical practice, the useful question now is whether your EHR vendor delivered the updates that apply to your system and whether those capabilities hold up in your real clinical and administrative workflows.

Two developments make that question harder than it looks. Some upcoming EHR deadlines come from later rules, HTI-2 and HTI-4. On top of that, a proposal called HTI-5, now in final review, could remove more than half of today’s certification criteria. Before sorting through any of that, it helps to be clear on what HTI-1 put into certified EHRs.

What HTI-1 Put Into Certified EHRs

HTI-1 stands for Health Data, Technology, and Interoperability, Certification Program Updates, Algorithm Transparency, and Information Sharing. ONC’s HTI-1 page explains that the rule updated the ONC Health IT Certification Program with new and revised standards and criteria that advance interoperability, support access to and exchange of electronic health information, and set transparency requirements for AI and other predictive algorithms in certified health IT.

The change your practice feels most is the data standard. USCDI Version 3 has replaced Version 1 as the baseline in the Certification Program, which shapes how clinical data is structured and exchanged. That standard sits underneath a longer list of HTI-1 updates, and that list is where your review should begin.

Which HTI-1 Updates Your EHR Should Already Have

ONC’s deadline table lists 15 criteria that HTI-1 revised. They fall into three groups.

• Clinical data and care coordination covers patient demographics and observations, family health history, social, psychological, and behavioral data, transitions of care, clinical information reconciliation and incorporation, and care plan.
• Patient access and APIs covers view, download, and transmit to 3rd party, application access for all data requests, and the standardized API for patient and population services.
• Reporting and documents covers the CQM filter, immunization registries, reportable lab results, cancer registries, electronic case reporting, and Consolidated CDA creation performance.

Under ONC’s enforcement discretion, developers had until that February grace period ended to finish these updates for every criterion on the list. Any certified module that carries these criteria should have the updated versions now.

So instead of asking “Are we HTI-1 compliant?”, a better question is “Does our certified module include the HTI-1 updates that apply to it, and do they work in our workflows?” You can start answering that from a public record before your vendor says a word.

Start With Your EHR’s CHPL Listing

ONC maintains the CHPL listing, the Certified Health IT Product List, which is the authoritative record of tested and certified Health IT Modules. Look up your product and write down a few things.

• The product name and version shown in the listing
• The § 170.315 criteria that version is certified to
• The certification status of that listing

Then compare it with the version your practice runs today. If the two differ, that gap becomes your first question for the vendor. Once you know which criteria your module carries, the next step is checking the data underneath them.

1. Check Your EHR’s USCDI v3 Support

USCDI v3 is the data set your certified EHR should now be built around. Ask your vendor these questions.

• Does our certified Health IT Module support the applicable USCDI v3 requirements?
• Which clinical data elements are supported, and are they available in the workflows we use?
• Can that information be exchanged through the supported interoperability methods?
• What documentation shows the relevant certification updates?

Expect v3 to stay the baseline for now, because ASTP/ONC withdrew proposals that would have adopted USCDI v4 and set an expiration date for v3. Gaps in USCDI support tend to surface first when a patient moves between care settings.

2. Test Transitions of Care

A transition of care is where missing or poorly structured data becomes a clinical problem. Pull a recent patient transition and check it.

• What information was sent and what was received?
• Was the clinical information structured appropriately?
• Could your clinician find the important details without rebuilding the patient’s history by hand?
• Did anything clinically important get lost, duplicated, or become hard to interpret?

This turns a certification discussion into a workflow test. Receiving the record is only half of that workflow, though, because the incoming data still has to fit into the existing chart.

3. Review Clinical Information Reconciliation

Reconciliation is how outside medications, allergies, problems, and documents get merged into your chart. Check what happens when outside information conflicts with what your chart already says, and whether clinicians can act on it without extra manual work.

This workflow deserves extra attention because its certification future is uncertain. A review of the HTI-5 proposed removals shows that criteria for CDA-based document exchange, including reconciliation at § 170.315(b)(2), are on the removal list, while the FHIR standardized API criterion at § 170.315(g)(10) stays. If the reconciliation criterion goes away, your clinicians will still need a workflow that works, so confirm your vendor plans to keep supporting it. Your own staff are one audience for that data, and your patients are another.

4. Test Patient Access and Third-Party Transmission

HTI-1 updated the view, download, and transmit criterion, so test it from the patient’s side rather than an administrator’s screen.

• Can patients view and download their information?
• Can they send it to a third party?
• Does the process work without staff stepping in manually?

Behind the patient portal, the apps that patients and partners connect to depend on something less visible, which is your API.

5. Review Your EHR’s API Capabilities

HTI-1 updated both the standardized API and the application access criteria, and the standardized FHIR API is one of the criteria HTI-5 would keep. Ask your vendor these questions.

• Which APIs and implementation guides are supported?
• What patient information can authorized apps access, and how is access authenticated?
• What documentation is available for developers and administrators?
• Are there limits on certain workflows or data elements?

This matters most if you use separate tools for patient engagement, remote monitoring, referrals, or analytics. When one of those tools can’t get the data it asks for, the question can shift from a technical one to a compliance one.

6. Review Information Blocking Exposure

Information blocking rules apply to healthcare providers, and for providers the test is whether you know a practice is unreasonable and likely to interfere with access, exchange, or use of electronic health information.

The stakes are specific. Under the federal disincentives rule, a MIPS eligible clinician found to have committed information blocking receives a zero in the Promoting Interoperability category, which carries 25% weight in the MIPS score. The HTI-5 proposal would also update the proposed definitions of access and use to cover automated means, including autonomous tools. That means requests made by software deserve the same attention as requests made by people.

Review situations like these.

• A patient requests their electronic health information.
• Another provider or a referral needs records.
• An app or automated tool requests access to available data.
• A technical limit prevents sharing in the requested way.

Document what was requested, what method was asked for, what you provided, and why any limit existed. Keep in mind that failing to meet an exception does not automatically mean information blocking occurred, since ONC reviews those situations case by case. Transparency questions also apply to the tools that shape clinical decisions.

7. Ask What Your EHR Does With AI and Predictive Decision Support

HTI-1 requires certified EHRs to show users source attributes for decision support, with a longer list for predictive tools than for evidence-based ones. Developers are responsible for the predictive tools they supply as part of their certified product. Ask your vendor these questions.

• Which decision support tools use predictive algorithms?
• What data inputs do they use?
• Where can clinicians see risk, limitation, and performance information?

Keep an eye on this area, because the HTI-5 proposed rule would narrow the decision support criterion and fully remove its AI model card requirements. That brings us to the rule that could reshape this whole checklist.

What HTI-5 Could Change About Your EHR Review

HTI-5 would remove 34 criteria, revise seven, and keep 19 of the 60 in the program, with the focus moving toward FHIR-based APIs. The final rule went to OMB review in August 2026, which is typically the last step before publication, and ONC’s site still lists HTI-5 as a proposed rule.

CMS is moving in parallel. Its latest CMS proposal for the Physician Fee Schedule would align the certified EHR technology definition used in MIPS with HTI-5.

For your practice, this changes a few things.

• A criterion dropping out of certification doesn’t mean your vendor has to remove the feature, so ask which functions they plan to keep.
• Get commitments for workflows you rely on, such as reconciliation, in writing or in your contract.
• Recheck your CHPL listing after the final rule is published.

While HTI-5 is still pending, two other deadlines are already locked in.

Separate the Deadlines Coming From HTI-2 and HTI-4

The same ONC deadline table lists decision support interventions at § 170.315(b)(11) under HTI-2, with privacy and security updates due by December 31, 2027. If your EHR includes certified decision support, ask what the vendor is changing and whether it affects your configuration.

Electronic prescribing shares that deadline, and it comes from HTI-4. According to the HTI-4 timeline, developers must update to NCPDP SCRIPT Version 2023011 and newer RxNorm and NDC code sets. Until the deadline, either SCRIPT 2017071 or 2023011 is allowed. Once it passes, only 2023011 is accepted, and the real-time prescription benefit criterion joins the Base EHR definition at the same time.

Electronic prior authorization is tied into this too. That same CMS proposal would make the MIPS Electronic Prior Authorization measure optional for its first year and required the year after. Ask your vendor these questions.

• Which SCRIPT version do we run now, and when do we move to 2023011?
• Will prescribing or prior authorization workflows change?
• Will pharmacy or other integrations be affected?

With this many rules in play, your vendor conversation needs a tighter script.

What to Ask Your EHR Vendor

Send your vendor a specific list instead of asking a broad compliance question.

• Which HTI-1 updates apply to our module, and were they delivered before the grace period ended?
• Does the version we run match our CHPL listing?
• Does it support USCDI v3 where applicable?
• How do transitions of care, reconciliation, and patient access work in our setup?
• Which APIs are available, and what can authorized apps access?
• What decision support information can our clinicians see?
• Which HTI-2 and HTI-4 changes arrive before the year-end deadline?
• If HTI-5 is finalized, which functions will you keep, change, or drop?
• Will any update require workflow, training, integration, or contract changes?

Get the answers in writing. Your vendor’s certification status and your practice’s daily use of the system are connected, but a clean CHPL listing can’t tell you whether your front desk can fulfill a records request in minutes.

The Real HTI-1 Question for Your Practice

That gap between a certificate and a working workflow is why HTI-1 belongs to your whole practice and not only your vendor. Start with the criteria in your CHPL listing, then test the matching workflows with your clinical, operations, IT, and compliance teams. When your vendor mentions “HTI-1 compliance,” ask which criterion, which update, which version, which deadline, and what changes your practice should expect, including anything HTI-5 might remove.