The EHR Association shared its feedback on two NPRMs recently: to ASTP/ONC regarding the 2025 Standards Version Advancement Process (SVAP), and to CMS regarding the FY 2026 IPPS proposed rule (CMS–1833–P).
Regarding the SVAP, the Association reiterated four points of feedback it has shared for previous versions “which the ONC has yet to address and that remain relevant to the new standard version.” These are:
- Aligning SVAP more directly with the cadence for publishing the annual FHIR US Core and C-CDA Companion Guide releases that support each annual version of USCDI. “As it currently stands, there is insufficient time to review and provide feedback on the FHIR US Core and C-CDA Companion Guide releases when their publication coincides with the closing of the SVAP comment period.”
- Confirmation from ASTP/ONC on the EHR developer community’s current understanding of policy related to partial implementation of a new version of a standard approved under SVAP without claiming support for that version under the SVAP. “…Developers are already implementing this approach and have not encountered any issues with client use in production environments. Therefore, we seek confirmation that our understanding aligns with ONC’s policy and expectations.”
- Concurrently available versions vs. the current SVAP structure that permits just one newly approved version to be available at any given time. This “is unnecessarily restrictive and does not align with typical development cycles or timelines.”
- A more precise and formal explanation of the dependencies between new standard versions.
Finally, the EHR Association also notes that the timeliness of conformance tools, which are essential for ensuring compliance with necessary rules, standards, and requirements, poses a significant challenge. “To address this, we must adopt a more efficient approach to tool updates and problem resolution, ideally by aligning the release of conformance test tools directly with the release of the SVAP standard.”
In sharing its IPPS feedback with CMS, the Association reiterated its commitment “to improving care delivery through the adoption of interoperable health IT…We support CMS’s continued focus on modernizing quality measurement and public health reporting while minimizing burden.”
Both letters are available on the Statements & Positions page of the EHR Association website