ONC's HTI-5 final rule removes 14 of 60 ONC Health IT Certification Program criteria and revises 7 others. The general effective date is 28 December 2026, with further removals on 1 January 2027. RCM leaders should get written EHR answers on feature scope, pricing, documentation export, and AI source attributes.
| Decision point | What HTI-5 does | What RCM should ask the EHR vendor |
|---|---|---|
| Certification criteria count | Removes 14, revises 7, leaves 39 unchanged (of 60) | Which removed criteria did our build rely on day to day? |
| AI transparency in decision support | Revises decision support interventions; removes model-card source-attribute requirements | How will AI suggestions still show source attributes for audit? |
| Timing | General effective date 28 December 2026; amendatory instructions 7, 10, and 12 on 1 January 2027 | Which modules change on which date in our version path? |
| Cost to developers | HHS projects more than $1.5 billion in regulatory cost savings | Will any previously certified feature move to a premium SKU? |
| Privacy and security criteria | Not removed in this final rule | Confirm privacy and security criteria remain in our certified stack |
Figures above come from the Federal Register HTI-5 final rule (91 FR 67916, 28 October 2026), the ONC HTI-5 overview fact sheet , the criteria removals and revisions fact sheet , and the HHS press release (26 October 2026).
What HTI-5 is
HTI-5 is the short name for "Health Data, Technology, and Interoperability: ONC Deregulatory Actions To Unleash Prosperity." ONC released the final rule on 26 October 2026. The Federal Register published it on 28 October 2026 at 91 FR 67916 (FR Doc. 2026-21943).
ONC proposed removing 34 of 60 criteria. The final rule removes 14 and revises 7. Thirty-nine criteria stay unchanged, including criteria added in the HTI-4 electronic prior authorization and real-time prescription benefit rule.
The ONC criteria fact sheet lists removals and revisions with timing. Removals on the general effective date include clinical decision support at Sec. 170.315(a)(9), security tags for summary of care send and receive, care plan, Consolidated CDA creation performance, and both Direct Project criteria. Removals effective 1 January 2027 include family health history, clinical quality measures filter, patient health information capture, automated numerator recording, automated measure calculation, and application access patient selection and all data request. Transitions of care is revised with a later effective date of 1 January 2030 for that revision path.
One substantial revision cuts the scope of the decision support interventions criterion. ONC removes the super intelligence "model card" requirements in Sec. 170.315(b)(11)(iv) and (v) for source attribute support, access, and modification. That change matters for AI trust conversations with hospital and RCM buyers, even though the rule writes to health IT developers, not to coding shops.
ONC did not finalize removal of dedicated privacy and security certification criteria in this rule.
Why RCM and coding leaders should care
HTI-5 is a developer certification rule. It does not rewrite ICD-10 or CPT. It still hits MediCodio AI's buyers because coding quality rides on what the EHR captures, exports, and keeps visible.
Three practical risks show up for VP RCM, HIM, and practice administrators:
- Feature drift into paid add-ons. When certification no longer requires a capability, vendors can still ship it, charge for it, or retire it. Practices that assumed "certified" meant "in our contract forever" need a written inventory.
- Documentation and export gaps. Removals around care plan, patient-generated health data capture, C-CDA creation performance, and certain application access criteria can change how complete charts arrive in coding queues. Incomplete documentation already slows billing companies. See incomplete documentation handoffs .
- Weaker default AI transparency. Dropping model-card source-attribute requirements for decision support interventions raises a fair buyer question: will clinicians and compliance still see why an AI suggestion appeared? Coding leaders who defend an audit trail should ask the same question of every AI tool in the chart path, including coding assist.
This sits next to the integration work covered in how to integrate EHR, coding, and billing software . Certification changes are one more reason to treat the EHR contract and the coding stack as linked systems. Related payer and fee-schedule pressure still sits in CY2027 PFS coding changes and payer-specific coding requirements for RCM .
A Monday checklist for coding ops
Trade coverage listed many practice steps after HTI-5. For coding and RCM leaders, compress that into a Monday list:
- Ask the EHR vendor for a written map of HTI-5 removals and revisions against your current certified product version.
- Mark every workflow coding depends on: problem list, meds, allergies, op notes, orders, C-CDA export, patient-generated attachments, quality measure extracts.
- Confirm which of those workflows stay in the base license after 28 December 2026 and 1 January 2027.
- Ask whether any previously included module moves to a premium SKU.
- Get the AI decision-support source-attribute behavior in writing, including what remains after model-card requirements drop.
- Re-test a sample of charts from each high-volume specialty for documentation completeness into the coding queue.
- Keep a 100% code-level audit trail on coded output so payer and compliance review does not depend on a vendor UI that may change.
How MediCodio AI fits beside a changing EHR
Complete charts flow through AutoPilot for fully autonomous coding. Charts where the documentation is thin or contradictory stay in CoPilot, where certified coders review and finalize the output. Nothing runs autonomous on day one. Your team widens the autonomous lane after first-pass accuracy is proven on your charts. MediCodio AI is EMR-agnostic, so coding ops can stay stable while vendors rearrange certification scope.
Approved claims that answer HTI-5 buyer objections:
- 100% code-level audit trail. Every code ships with its documentation passage and the compliance rule behind it. That stays true even when EHR AI transparency defaults shrink.
- 1.5 min to code a chart on CODIO AI's first pass, before review.
- 98%+ coding accuracy / coded right the first time. That figure is first-pass accuracy across deployments since 2023, measured at the code level on production charts before any correction, against a reference review by AAPC- and AHIMA-credentialed coders applying official guidelines and payer policy to the same documentation.
Related reading
- How to Integrate EHR, Coding, and Billing Software
- What Do You Do When a Client's Documentation Is Incomplete?
- What Are Payer-Specific Coding Requirements in RCM?
- CY2027 Physician Fee Schedule Final Rule: Coding Changes
Sources
- Office of the National Coordinator for Health Information Technology / HHS, Health Data, Technology, and Interoperability: ONC Deregulatory Actions To Unleash Prosperity , 91 FR 67916 (28 October 2026). Effective dates, 14 removals, 7 revisions, model-card removal.
- ONC, HTI-5 Final Rule Overview fact sheet (26 October 2026).
- ONC, HTI-5 Final Rule Removals or Revisions of Certification Criteria (26 October 2026). Criterion-by-criterion timing table.
- HHS, HHS Finalizes HTI-5 Deregulatory Rule... (26 October 2026). More than $1.5 billion projected regulatory cost savings.
Frequently asked questions
Does HTI-5 change ICD-10 or CPT codes?
No. HTI-5 amends ONC Health IT Certification Program criteria under 45 CFR part 170. Coding tables and Medicare payment rules sit elsewhere. The RCM impact is documentation capture, export, vendor pricing, and AI transparency defaults inside the EHR that feeds the coding queue each day.
When do HTI-5 changes take effect?
The final rule's general effective date is 28 December 2026. Amendatory instructions 7, 10, and 12 are effective 1 January 2027. Some revised criteria use later dates. The transitions of care revision path includes a 1 January 2030 effective date. Use the ONC criteria fact sheet for each criterion's timing.
Did ONC remove privacy and security certification criteria?
No. The HTI-5 final rule did not finalize removal of the dedicated privacy and security certification criteria. Those proposals remain for possible future rulemaking. Buyers should still confirm their vendor's current certified privacy and security modules in writing before renewal.
What happened to AI model-card requirements?
ONC revised the decision support interventions certification criterion and removed the super intelligence model-card source-attribute requirements in Sec. 170.315(b)(11)(iv) and (v). Buyers should still ask EHR and AI vendors how source attributes appear for clinicians and auditors after those certification requirements drop.
How does MediCodio AI help if our EHR features change?
Complete charts flow through AutoPilot for fully autonomous coding. Charts where the documentation is thin or contradictory stay in CoPilot, where certified coders review and finalize the output. A 100% code-level audit trail and about 1.5 minutes for a first-pass chart keep coding ops steady while you renegotiate EHR scope.
Book a Demo
If your hospital, ASC, physician group, or RCM firm needs coding that stays auditable while EHR certification scope changes, Book a Demo and run the workflow on your own charts.