HTI-5: Five Questions for Your DPC EHR Vendor

HTI-5 changes federal health IT certification requirements. For a DPC practice, my recommendation is to ask your EHR vendor what will change in your actual product, test the workflows you depend on, and get the implementation plan in writing before making a purchasing decision.

I would not replace a working EHR because a regulatory headline says the rules have changed. I would ask the vendor to explain what that headline means for the physician, the staff, and the patient using its software.

HHS announced the HTI-5 final rule on October 26, 2026. Its official announcement describes changes intended to reduce the certification burden on health IT developers. The question for a practice owner is narrower: what will change in the software you use, and what work will that create for your team?

What changed, and when?

The October 28 final rule revises and removes selected certification provisions. It generally takes effect December 28, 2026, with certain amendments effective January 1, 2027 and additional provision-specific transition dates. Ask about the provisions relevant to your product, rather than treating one date as the deadline for every function.

Two examples show why the details matter. The rule retains the clinical-information reconciliation criterion with revisions; it does not simply eliminate reconciliation. It also changes safety-enhanced-design certification to an attestation-based approach. Neither fact tells you how your vendor will implement its next release.

There is another important boundary: HHS says the proposed information-blocking changes remain under consideration. Do not treat those proposals as finalized by this announcement.

Should a DPC practice change EHRs now?

Not on the headline alone. First separate three questions:

If certification matters to your use case, verify the exact module and version in the Certified Health IT Product List. Then use our DPC EMR evaluation framework for the broader purchasing decision. This article is about responding to this rule, not another software ranking.

Which workflows would I ask the vendor to demonstrate?

Use fictional records in a demonstration environment. Do not send patient information through a sales form or an unapproved tool.

Reconcile an outside record. Have the vendor show how a physician checks an incoming medication list, resolves a discrepancy, and confirms the final record. Ask what changes after the relevant release and what evidence remains available to review the action.

Retrieve a patient's information. Ask staff to demonstrate the practice's records-access process and show a sample export. Check what the file contains and who can use it. A successful download is not the same as a usable transition to another system.

Handle a staff change or an outage. Walk through removing access, recovering an account, and finding the information needed to continue an agreed downtime workflow. Ask who owns each step on the vendor side and inside the practice.

These are my operating checks, not a claim that HTI-5 requires every demonstration above. Keep legal applicability separate: HHS explains that HIPAA duties depend on covered-entity and business-associate status. Confirm your practice's obligations with qualified advisers.

What should the vendor put in writing?

I would leave the conversation with a short, specific record:

"We are compliant" is not a substitute for those answers. If the vendor has no product change planned, document that answer too. There is no value in manufacturing an implementation project your practice does not need.

Where can Freedom Healthworks help?

Software decisions become operating work: someone needs to coordinate the release, prepare staff, and resolve vendor questions. Through the agreed scope of our practice management support, Freedom Healthworks can help organize those responsibilities and the administrative workflows around the technology. The selected tier and signed agreement define what we handle. We do not certify vendors, determine legal compliance, or make clinical decisions for the physician.

If an upcoming software change is creating uncertainty, bring the vendor's release notice and your unresolved workflow questions to a practice consultation. Start with what your practice actually needs to do, then decide whether anything needs to change.

Sources rechecked November 13, 2026. This is operating guidance, not a determination of a product's certification or your practice's legal obligations.