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Here's how today's HTI-2 Final Rule stacks up against @SMARTHealthIT comments (thanks Gemini Experimental!)
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Here's a breakdown, organized by the topics you raised in your comments:
1. FHIR Bulk Data Enhancements
Export Performance Parity:
Status: NOT ADDRESSED in this final rule. This was one of the more ambitious proposals, and it seems ASTP/ONC has decided to defer it for later consideration. This topic falls under the broader category of proposals from HTI-2 that were not addressed in this particular rule.
Assessment: Feedback not heeded in this final rule; likely deferred.
Server Support for Patient Group Creation:
Status: NOT ADDRESSED in this final rule. Similar to export performance parity, this was likely deferred. ASTP/ONC has acknowledged the early work in the Argonaut Project but has not yet taken action to incorporate it into the regulations.
Assessment: Feedback not heeded in this final rule; likely deferred.
Server Support for _since and _type:
Status: NOT ADDRESSED in this final rule. This proposal, while valuable, was likely deemed less urgent than other priorities addressed in this partial final rule.
Assessment: Feedback not heeded in this final rule; likely deferred.
2. EHI Export
Status: NOT ADDRESSED in this final rule. Your recommendations for enhancing EHI Export, including download functionality in patient portals, third-party app access, and handling of non-computable formats, were not part of this partial final rule. These are significant proposals that likely require more consideration and potentially a separate rulemaking process.
Assessment: Feedback not heeded in this final rule; likely deferred.
3. Image Links in API Responses
Status: NOT ADDRESSED in this final rule. The specifics of image access via API were not covered in this partial final rule. Your concerns about the shareability and programmatic accessibility of "imaging links" remain unaddressed for now.
Assessment: Feedback not heeded in this final rule; likely deferred.
4. Subscriptions for US Core Data
Status: NOT ADDRESSED in this final rule. The proposal to require subscription capabilities for US Core data was not included in this partial final rule. Your recommendations regarding a phased approach, alignment with Argonaut's work, and specific technical details were not acted upon at this time.
Assessment: Feedback not heeded in this final rule; likely deferred.
5. Dynamic Registration outside of Trust Frameworks
Status: NOT ADDRESSED in this final rule. The proposal to adopt dynamic registration, along with your recommendation to support self-signed certificates, was deferred.
Assessment: Feedback not heeded in this final rule; likely deferred.
6. CDS Hooks
Status: NOT ADDRESSED in this final rule. The inclusion of CDS Hooks 2.0 in the certification requirements was not part of this partial final rule.
Assessment: Feedback not heeded in this final rule; likely deferred.
Overall Assessment
This final rule primarily focused on establishing the regulatory framework for TEFCA and making some limited updates to the ONC Health IT Certification Program. It did not address the majority of the substantive proposals in your comments, which were largely related to:
Enhancements to FHIR Bulk Data Access
Improvements to EHI Export
Specific API requirements for image access
Implementation of subscriptions for US Core data
Details of dynamic registration
Adoption of CDS Hooks
It's important to reiterate that the absence of these topics in this final rule does not necessarily mean they have been rejected. ASTP/ONC has explicitly stated that the remaining proposals from HTI-2 are still under consideration for future rulemaking. It's likely that your comments will be taken into account as they develop those future rules.
It may be worthwhile to follow up with ASTP/ONC during future comment periods or through other engagement channels to reiterate your recommendations and track their progress.
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