Interoperability

HEALTH POLICY BRIEF — Thursday, September 24

ONC owns today’s clock. Its USCDI Version 8 input window closes Monday, September 28, at 11:59 p.m.

Matt Reid

— 2 min read
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Executive Briefing

ONC owns today’s clock. Its USCDI Version 8 input window closes Monday, September 28, at 11:59 p.m. ET. This is not a current new physician mandate or certification deadline; it is the last practical checkpoint for recommending new data elements or commenting on existing ones before ONC targets Draft USCDI v8 for January 2027. Policy relevance: run a rapid gap check centered on clinical validity, workflow feasibility, implementation maturity, and vendor—not practice—cost and accountability. ONC, Standards Bulletin 2026-2, July 23, 2026 (https://healthit.gov/standards-and-technology/onc-standards-bulletin/onc-standards-bulletin-2026-2/#uscdi-v8-submission-period)

ONC also released USCDI+ Quality Version 2, aligning the dataset with USCDI v6 and updating elements used for CMS eCQMs and FHIR-based quality reporting. That is a specification update, not by itself a clinician-reporting or EHR-certification requirement. Physician policy angle: compare the new elements and vocabularies with current quality workflows; the test is whether alignment removes duplicate capture and validation or merely gives the burden a cleaner FHIR wrapper. ONC, Announcing the Release of USCDI+ Quality Version 2, September 2026 (https://uscdiplus.healthit.gov/uscdiplus/en/announcing-the-release-of-uscdi-quality-version-2-september-2026?id=kb_article&table=kb_knowledge&sys_id=8622128a3b57c3103cb59d0864e45a60&view=sp)

CMS opened an RFI on the “reasonable and relevant” standard contract terms Part D sponsors must offer pharmacies beginning with plan year 2029; comments close November 23. The future standards are not set, and this is not a direct physician-payment change or practice mandate. The pressure point is pharmacy-network participation, patient access, and plan-sponsor leverage. Triage the questions now for access, transparency, contracting, and accountability hooks. CMS/Federal Register, Medicare Part D Reasonable and Relevant Pharmacy Contracting Standards, September 24, 2026 (https://www.federalregister.gov/documents/2026/09/24/2026-19535/request-for-information-medicare-part-d-reasonable-and-relevant-pharmacy-contracting-standards)

Digital Health / Privacy / Interoperability

ONC and OCR’s Security Risk Assessment Tool v3.7 adds prompts on multi-location scope, remote access and telework, asset inventories, system logging, and review triggers. It is aimed at small and medium providers, stores entered information locally, and remains optional: completion does not guarantee HIPAA compliance. Review whether the additions help resource-constrained practices find real risks without mistaking a checklist for a safe harbor. ONC, Security Risk Assessment Tool, updated September 18, 2026 (https://healthit.gov/privacy-security/security-risk-assessment-tool/)

Federal Health Policy Watch

FDA and HRSA are asking whether unmodified deceased-donor islet cells for Type 1 diabetes should be treated as organs under HRSA and OPTN oversight; comments close November 9. That could shift processing, allocation, surveillance, training, and transplant-program expectations. Route for a quick access-and-clinical-standards read before deciding whether comments are warranted. HHS/Federal Register, Improving Patient Access to Deceased Donor Islet Cells and Cell Products, September 24, 2026 (https://www.federalregister.gov/documents/2026/09/24/2026-19563/improving-patient-access-to-deceased-donor-islet-cells-and-cell-products-request-for-information)

Policy Action Implications

  • By Monday: decide whether to submit targeted USCDI v8 recommendations and/or comments on existing elements.
  • This week: map USCDI+ Quality v2 against CMS eCQM/FHIR workflows and flag practice-facing capture or validation shifts.
  • For CMS: build a short Part D RFI issue map and decide comment strategy well before November 23.
  • Monitor: test SRA Tool v3.7 against common small-practice cyber gaps; route the islet-cell RFI for specialist review.

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