ASTP ONC RWT Enforcement Discretion

ONC Enforcement Discretion for 2026 RWT Plan Submission Offers Flexibility, but Value Remains in Participation

On June 30, 2025, the Assistant Secretary for Technology Policy/ Office of the National Coordinator for Health Information Technology (ASTP/ONC) issued an enforcement discretion notice stating it will not enforce submission of a Real-World Testing (RWT) Plan for the 2025 calendar year. While this gives developers more flexibility, the RWT condition remains a requirement of the ONC Health IT Certification Program. Developers should weigh their options carefully.

For certified developers with application programming interface (API) criteria (g.7, g.9–g.10), the obligation to submit RWT Results for calendar year 2025 remains in place and is still due in Q1 2026.

A Chance to Refocus the Purpose of RWT

ASTP/ONC’s decision not to enforce the 2026 Plan submission offers a chance to revisit the process on your own terms. Developers who choose to proceed voluntarily can use this flexibility to shape RWT around what matters most to their product performance, user experience, and/or business goals.

Instead of focusing only on regulatory alignment, this year can be used to:

• Test functionalities used and valued by your customers
• Streamline data collection methods that support other analytics or QA goals
• Align RWT metrics with internal product roadmaps, customer outcomes, or Insights measures

By treating RWT as a strategic insight tool rather than a checkbox requirement, developers can get more value out of the process—and be better prepared when enforcement resumes.

Why Consider Submitting an RWT Plan Anyway?

Even without enforcement this year, voluntarily preparing and submitting a 2025 RWT Plan offers measurable benefits. Here’s why:

1. Maintain Readiness for Future Cycles
   RWT is a recurring requirement. Skipping a plan year can cause knowledge gaps and documentation setbacks, and customer disengagement to collaborate on RWT. Developers who maintain continuity will be better prepared when enforcement resumes. Submitting a plan this year reinforces internal workflows and preserves institutional memory.
2. Identify Issues Before They Become Problems
   The plan and results review process help identify overlooked gaps in implementation, such as incorrect use cases or incomplete measures. Many developers use Drummond’s RWT review to spot data quality issues, incomplete patient scenarios, or inconsistencies in metrics tied to certification criteria.
3. Validate Real-World Alignment with Certification
   Certification shows your product met a technical standard in a test environment. RWT validates whether your product continues to perform as intended in actual production settings. This helps you demonstrate to customers, partners, and regulators that your product supports real-world interoperability and increases your product’s credibility.
4. Support Continuous Improvement
   RWT fosters internal discussion around product enhancements, interoperability tracking, and stakeholder engagement. You can use RWT findings to adjust roadmaps, align with customer needs, and prioritize fixes before they impact users.
5. Reinforce Stakeholder Trust
   When you voluntarily demonstrate how your certified product functions in the field, it shows transparency, credibility, and accountability. Providers, payers, and customers value that commitment, especially when the testing is proactive and independently reviewed.
6. Benefit from Proctor Feedback
   Drummond’s RWT Plan Review includes a live session with a proctor. Developers routinely describe this type of 1:1 conversation as one of the most useful parts of their participation. The session clarifies technical ambiguities, offers tips for result tracking, and helps developers meet expectations without guesswork.
7. Leverage for Sales and Market Credibility
   RWT plans and results can be used to support marketing claims, proposal responses, or onboarding documentation. Even when not enforced, your RWT activity shows compliance maturity and real-world credibility.

What Developers Should Know

This enforcement discretion applies only to the RWT Plan submission for the 2025 calendar year. It does not suspend the RWT condition entirely. The program’s requirement remains in place, and other elements of ONC’s Health IT Certification Program continue unchanged.

For health IT products certified to API criteria (g.7, g.9-g.10), the 2025 RWT Results submission (based on the 2025 plan submitted in 2024) is still required in early 2026. Stay Proactive

Even without full enforcement this year, RWT remains a critical part of demonstrating that your certified technology continues to work as intended in real clinical care settings. Taking action now keeps your team synchronized with ONC expectations and avoids the burden of catching up later.

You may not be required to submit a 2026 plan in 2025, but continuing to do so can improve your product, support your customers, and strengthen your compliance posture. It’s a practical investment in the long-term success of your certification.

For the full ONC announcement, visit:
https://www.healthit.gov/topic/real-world-testing-condition-and-maintenance-certification-requirements-enforcement

Contact your Drummond Account Manager if you have any questions about how this may impact your ONC Health IT Certification.