SMART Health IT team submitted formal comments on HTI-5. Feel free to read and borrow language. Briefly: Deregulation should not mean losing sight of whether interoperability is actually working. (HTI-5 risks eliminating the instrumentation ASTP/ONC needs to steer a successful transition to FHIR-based exchange.)

Three priorities: 1) ensure AI agents cannot be priced or contracted out of access, 2) preserve Real World Testing for full EHI export, and 3) retain meaningful Bulk FHIR observability metrics.

“Full comment including suggestions for HTI-6: https://lnkd.in/gGRpTJxh