In March 2025, the Assistant Secretary for Technology Policy (ASTP) and the Office of the National Coordinator for Health Information Technology (ONC) (collectively, ASTP/ONC) announced that they will pause enforcement of most reporting requirements tied to the “Insights” Condition and Maintenance of Certification.
This decision follows Executive Order 14192, Unleashing Prosperity Through Deregulation, signed on January 31, 2025. The order directs federal agencies to reduce unnecessary regulatory costs, especially in cases where organizations might spend time and resources on rules that could later change. In this case, the goal is to prevent health IT developers from investing in systems or processes that might be revised or rolled back.
What the Pause Covers
Under the HTI-1 final rule, developers were expected to begin collecting data in 2026 and start reporting on seven new “Insights” measures beginning in July 2027. Full reporting across all measures was set to ramp up by 2029.
With this enforcement pause, ASTP/ONC has clarified the following:
- Only one measure will be enforced
Developers must still report on the “use of FHIR in apps through certified health IT” measure, found in 45 CFR 170.407(a)(3)(iv).- Parts (A) and (B) will be due starting in July 2027
- Part (C) will be due starting in July 2028
- The other six measures are on hold
ASTP/ONC will not enforce reporting on the remaining six Insights measures during this period. - Certification bodies impact
ONC-Authorized Certification Bodies (ONC-ACBs) will not be will not be enforcing reporting on measures other than for the use of FHIR for certifying developers who only submit data for the required FHIR-related measure.
*All developers must report annually either 1) A measure response or 2) An attestation that they do not have at least 50 hospital sites or 500 clinician users across their certified health IT, do not have certified technology for a measure, and do not have users for that certified functionality.
What Developers Should Know
Developers should note that this enforcement discretion does not change the rule itself. The Insights requirements remain in place, but ASTP/ONC is choosing not to enforce most of them for now. This pause will stay in effect until the Department of Health and Human Services (HHS) officially updates or removes the relevant regulations.
Additionally, ONC has clarified that Health IT Modules may implement either the December 2022 or the March 2024 version of the “Standardized Data for Research” specification (including the Insights Condition at §170.315(b)(10)(i)(B)) to meet certification requirements. This provides developers with flexibility to align implementation with current capabilities while remaining compliant. While use of the March 2024 version is encouraged, it is not required at this time.
Developers should focus on preparing for the FHIR measure reporting in 2027 and 2028 by gathering data in July 2026. Work related to the other Insights measures can be deferred unless or until future guidance says otherwise.