ONC HTI-1 and HTI-4 Compliance: 2026 Buyer Checklist for EHR Teams

What HTI Changed for Buyers

HTI rulemaking (including HTI-1 and subsequent updates) expands expectations around certified health IT behavior, including interoperability commitments and transparency in predictive decision support artifacts. Buyers should treat this as both a compliance and vendor-risk topic.

• Interoperability posture: stronger scrutiny on real-world API performance and data usability, not just checkbox certification.
• Algorithm governance: buyers need to understand provenance, limitations, and monitoring of decision-support outputs.
• Information blocking exposure: procurement and operations teams need defensible workflows when data exchange fails.

2026 Buyer Checklist

Certification and Version Control

• Verify active product listings in ONC CHPL for every module you plan to deploy.
• Require vendor disclosure of certified version vs. your contracted release train.
• Document any known timeline gaps between federal requirement dates and your tenant availability.

Predictive/Decision Support Transparency

• Request model documentation, intended use, contraindications, and performance caveats.
• Require role-based controls to turn features on/off by specialty, location, or user group.
• Define internal post-deployment monitoring metrics before activation.

Data Export and Exit Readiness

• Contract for routine export tests (not just a promise at termination).
• Require standard formats and clear documentation for extraction cadence and cost.
• Assign an internal data stewardship owner for periodic validation drills.

Contract Language You Should Add

1. Regulatory maintenance clause: vendor commits to maintain certified capabilities within defined windows.
2. Transparency clause: vendor provides decision-support documentation and material change notices.
3. Interoperability SLA: response-time and defect-remediation obligations for data exchange failures.
4. Exit clause: bounded data-export fees and timeline guarantees.

Governance Model (Provider Side)

Create a cross-functional HTI committee with representation from clinical operations, IT, compliance, security, and revenue cycle. Meet monthly with a standing agenda: certification status, interoperability incidents, decision-support changes, and remediation queue.

Executive Scorecard

• Percent of required interfaces meeting SLA
• Count of unresolved interoperability defects older than 30 days
• Percent of high-impact decision-support tools with completed governance review
• Quarterly export test pass rate

Pair this with our selection framework and interoperability guide to operationalize requirements before contract signature.