Your Chief AI Officer · Thursday, November 5, 2026 · Act today

HHS cut 14 EHR certification rules, and the checklist shrinks Dec. 28

Reported1 sourceFor employees and patients

The federal certification checklist behind practice EHRs shrinks on Dec. 28 after HHS cut 14 EHR certification rules, Physicians Practice reported. The article advises practices to lock down EHR contracts, MIPS reporting and referral workflows while they have leverage.

On Dec. 28, the federal certification checklist behind practice EHRs gets shorter. The HTI-5 final rule, released by HHS on Oct. 26, removes 14 of the 60 criteria in the health IT certification program run by the Office of the National Coordinator for Health IT and revises seven more, Physicians Practice reported. HHS projects more than $1.5 billion in savings, according to the same report. That is a projection, and it is aimed at developers. Tom Keane, M.D., the national coordinator for health IT, said the rule will "significantly lower the administrative compliance burden for developers."

The question for provider organizations is where the burden goes next. Commenters on the rule warned that dropped functions could become "premium features that providers must purchase to achieve necessary functionality." ONC replied in the final rule that it does not believe users will see a significant increase in overall costs. MGMA told regulators in February that the proposal would push "technical, operational and compliance responsibilities downstream to medical groups," Physicians Practice reported.

Two facts temper the risk. The final rule cut far fewer than the 34 criteria first proposed, and nothing goes dark on Dec. 28, per Physicians Practice. But a removed criterion is no longer a federal requirement, so what a vendor keeps, supports and charges for becomes a contract matter rather than a regulatory one. There is no data yet on how vendors will respond, and the savings estimate does not tell you whether any of it reaches the practice.

For CIOs and CTOs, the work is an inventory: which capabilities in daily use, from referral exchange to MIPS reporting outputs, trace back to the removed or revised criteria. For compliance and legal, the work is language: support obligations, pricing protections and notice periods for any change to those functions. For the Chief AI Officer, it is a reminder that EHR roadmaps now carry more vendor discretion, which affects any AI tooling that depends on those data flows.

The move is to review the EHR contract for capabilities that relied on the removed certification criteria and get commitments in writing before Dec. 28, while practices still have leverage. Protecting those workflows keeps referrals moving and reporting intact, which spares staff from building workarounds and keeps patient information flowing where care teams need it.

Do this week. Review your EHR contract for capabilities that relied on the removed certification criteria and get commitments in writing before Dec. 28.

Run this

The prompt to act on this item, for your own model.

Paste it into Claude, ChatGPT or Copilot and fill the bracketed slots with your own numbers. The output is a draft for your team to check, built only from the sources on this page. Never paste patient data. How these prompts are written.

You are an advisor to the CIO and the compliance and legal lead of [your organization], preparing us to secure written EHR contract commitments before a federal deadline.

Context: Physicians Practice reported that the HTI-5 final rule, released by HHS on Oct. 26, removes 14 of the 60 criteria in the health IT certification program run by the Office of the National Coordinator for Health IT and revises seven more, with the checklist shrinking on Dec. 28. The final rule cut far fewer than the 34 criteria first proposed, and nothing goes dark on Dec. 28. HHS projects more than $1.5 billion in savings, a projection aimed at developers. Commenters warned that dropped functions could become "premium features that providers must purchase to achieve necessary functionality." ONC replied that it does not believe users will see a significant increase in overall costs. MGMA warned of responsibilities pushed "downstream to medical groups." There is no data yet on how vendors will respond. A removed criterion is no longer a federal requirement, so what a vendor keeps, supports and charges for becomes a contract matter.

Task: Using the capabilities I list, identify which may trace back to the removed or revised criteria, then draft the questions and written commitments we should request from our vendor before Dec. 28.

Output: a vendor question list for the executive team, grouped by capability. For each item give the question, the written commitment we want (support obligation, pricing protection, notice period for changes), our internal owner, and what must be verified. End with a short note on any AI tooling that depends on these data flows.

My inputs: [your EHR vendor and product], [the capabilities in daily use, such as referral exchange and MIPS reporting outputs], [your contract term and renewal date], [current contract language on support, pricing and notice], [your internal owners for IT and legal].

Guardrails: Use only the facts above and the inputs I fill in. Cite Physicians Practice by name. Flag anything uncertain, and note that the specific removed criteria must be verified against the rule itself. Do not request or include any patient data. This is a draft for our team to check, not legal or medical advice.

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The claim.
Physicians Practice says practices have leverage now to protect contract terms, MIPS reporting and referral workflows.
The evidence.
The change is reported by Physicians Practice; no data yet on how vendors will respond.

By seat

For the Chief AI Officer. Check which AI tools depend on EHR interfaces that were certification requirements and confirm they stay supported.

For the CIO and CTO. Ask the EHR vendor to confirm in writing which affected functions it will keep.

For the Compliance, privacy and legal. Confirm MIPS reporting will not be disrupted by the change.

Checked before publishing. 2 independent outlets. 1 figure matched to the source text. Also reported by HIT Consultant Media.

Sources

  1. Physicians Practice, 18 ways to protect your practice now that HHS cut 14 EHR certification rules

Drafted by Lumen from the sources above, scored by a second pass on six criteria, then checked by rule against those sources (every figure, two independent outlets or a primary source) and published only when it passes. A person can pull any item, and corrections are published here. Apolitical, always. Nothing here is medical advice. How Your Chief AI Officer is made.

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