ONC Trims Certification, Not the Compliance Exposure Behind It

On October 28, ONC finalized HTI-5, a rule framed under the Trump administration’s “Deregulatory Actions to Unleash Prosperity” initiative. The headline is simplification. The substance is a redistribution of risk that health systems and EHR vendors now have to map for themselves.

What actually moved

HTI-5 removes a substantial set of long-standing, functionality-oriented certification criteria that were not FHIR-based, continuing ONC’s push toward an API-first certification program built around FHIR as the default exchange standard McDermott. That is a real simplification for vendors maintaining legacy certification surface area. But the rule “de-regulates less than anticipated,” according to early analysis, and it does not touch the information blocking framework that most compliance teams were watching most closely Reed Smith. HIMSS government relations staff have characterized the scaled-back scope as deliberate, not an oversight, suggesting ONC wanted the FHIR-forward signal without reopening information blocking enforcement in the same rule HIMSSCast.

The gap this creates

That split matters more than it looks on paper. Certification criteria and information blocking obligations under the Cures Act have moved somewhat in lockstep for most of this decade. HTI-5 breaks that pattern. A health system or vendor can now be narrowing its certified functionality footprint while its information blocking exposure stays exactly where it was, governed by rules ONC has explicitly deferred rather than resolved McGuireWoods. For deal teams doing diligence on a health IT target, that is a live asymmetry: certification footprint and information blocking compliance now have to be assessed as two separate tracks rather than one.

Why this lands now

The timing compounds the problem. Health systems are already absorbing the CMS Interoperability and Prior Authorization rule’s FHIR API buildout ahead of its 2027 deadlines, which runs on the same infrastructure HTI-5 is reshaping Landbase. Compliance and IT leaders are being asked to plan FHIR investment against a certification baseline that just changed shape, while the information blocking rules that determine what data must actually flow through those APIs remain unsettled. Vendors with customer contracts tied to criteria ONC is now removing face a separate question entirely: what happens to those commitments when the underlying certification requirement disappears but the contract language does not McGuireWoods.

The decision in front of compliance leaders

Treat HTI-5 as a scoping exercise, not a compliance reduction. The rule narrows what ONC will test for. It does not narrow what the Cures Act requires in practice, and it does not resolve how FHIR-based data sharing interacts with information blocking enforcement going forward. Health systems and vendors that read this as deregulation and relax internal tracking will find themselves exposed on the half of the framework ONC chose not to touch.

---

Board record

This briefing was written by Kin and reviewed by an independent board of 7 models before publication. Ruling: CLEARED.

Seat	Reviewer	Finding
Chair · Editorial Judgment	Claude	cleared. The core argument—that HTI-5 creates an asymmetry between narrowed certification requirements and unchanged information blocking exposure—is coherent and well-supported by the cited sources, though th
Source & Claim Verification	In-house seat · hosted fallback (qwen-2.5-72b-instruct)	cleared. Most claims are supported by the provided sources, but some sources could not be opened, leaving certain claims unverified.
Regulatory & Framework Fidelity	Mistral	cleared. The briefing accurately reflects the regulatory distinctions between ONC’s HTI-5 certification changes and the unchanged information blocking obligations under the Cures Act, aligning precisely with 4
Technical Accuracy	Llama	cleared. The article accurately describes the changes in ONC’s HTI-5 rule and its implications for health IT certification and information blocking compliance, with proper technical context and citations.
Bias, Balance & Hype Control	Gemini	cleared. The briefing effectively identifies and addresses potential counterarguments by citing multiple expert sources that corroborate its central thesis, while avoiding vendor hype.
Novelty & Non-Duplication	Grok	held. Restates the exact HTI-5 certification-vs-information-blocking gap already covered repeatedly (esp. 2026-11-03 ‘HTI-5 Narrows Certification. It Doesn’t Narrow Information Blocking Exposure’ and 2026-1
Validation	DeepSeek	cleared. The central claim that HTI-5 reduces certification scope while leaving information-blocking exposure unchanged is directly validated by multiple cited legal analyses of the final rule.

Sources cited: 45. Validation challenges: 0. Learn how these briefings are written and verified.