Keep Bulk Data API Certification Current with FHIR Bulk Data Specifications

Recommendation: The ONC Health IT Certification Program must ensure certified Health IT systems implement current, stable, industry-adopted versions of the FHIR Bulk Data Access (Flat FHIR) specification to support efficient, population-level export of USCDI data.

Rationale & Specifics: To enable scalable population health, research, and system transition use cases:

1. Essential Parameter Support: Mandate support for critical FHIR Bulk Data parameters, including _since for incremental updates and _typeFilter (or equivalent mechanisms) for granular data scoping of exported resources. Certification must validate correct implementation. Incremental updates enable systems to use efficient bulk exports that only contain required data and can be processed rapidly. In contrast to notifications when there are changes, incremental export requests represent a simpler approach to integration, support export of historical data, and do not require both the data provider system and the data consumer system to be continuously online.
2. Basic Group Management: Require EHR systems to support standardized API-based creation, modification, and deletion of FHIR Group resources for use in Bulk FHIR exports, without arbitrary group size limitations. Signal intent to adopt community-developed standards via SVAP for more advanced group management capabilities. Group APIs for both roster based groups (e.g., the DaVinci Member Attribution List Implementation Guide) and characteristic based groups (e.g., Argonaut work on FHIR Group API for Bulk Data Access IG) are needed to fully realize the potential of the Bulk Data API.