The HHS Office of Inspector General is still conducting investigations. ONC says it is issuing notices of nonconformity to certified developers, and the scope of those notices is not yet public. The College of American Pathologists and other groups opposed removing the AI transparency requirements. ONC did not address information blocking in the final rule, so existing information blocking regulations remain in force. The final rule also scaled back considerably from the December 2025 proposal, which would have removed 34 criteria. ONC declined to finalize the proposed removal of privacy and security criteria and kept the electronic prior authorization and real-time prescription benefit criteria added under HTI-4. HHS projects more than $1.5 billion in regulatory cost savings.
Vendors should map their certification obligations now. Many changes take effect 60 days after Federal Register publication, and others start January 1, 2027. Proposals ONC did not finalize, including the information blocking changes, remain under consideration and could return in later rulemaking, so attorneys should track the docket.