Analysis

HHS finalized 14 health-IT certification criterion removals on October 28, compared with 34 in its December 29, 2025 proposal. The final rule leaves 39 of 60 criteria unchanged, or 65%. The narrower rule still removes decision-support disclosure and predictive-risk duties that help hospitals evaluate tools.

The December 29 proposal, page 11, divides the 60 criteria into 34 removals, seven revisions and 19 unchanged. Secretary Robert F. Kennedy, Jr., signed the proposal on page 208. The October 28 final rule, pages 6–7, instead lists 14 removals, seven revisions and 39 unchanged.

The arithmetic is direct: 34 − 14 = 20 fewer removals; 39 − 19 = 20 more unchanged. Each partition totals 60. The unchanged share is 39 ÷ 60 × 100 = 65%.

Those counts measure the number of criteria. They do not measure clinical importance, the number of patients affected or the financial value of the requirements. No conversion from a count of criteria to a count of lives protected is supported.

The identical seven-criterion revision totals also do not mean identical criteria were revised. Page 217 of the final rule says safety-enhanced design was proposed for removal and instead revised. The movement between categories prevents treating the numerical difference as proof that 20 particular safeguards were fully restored.

The final rule's page 6 leaves proposals not discussed in this rule under consideration. The published partition describes what this final rule does; it is not evidence that every other proposal has been abandoned.

The surviving deletions include § 170.315(b)(11)(iv) through (vi), removed by amendment 11(g). These cover decision-support source information, access and modification, and predictive risk management. The related maintenance provision is also removed.

ONC argues that the transparency requirements imposed burdens without published evidence it could identify of improved patient care or purchaser evaluation. The agency expects useful information to be shared voluntarily. That defense concerns whether the duties earned their cost, not whether the final rule deletes them.

Developers are the direct beneficiaries in ONC's model of reduced certification work. Actual additional purchaser bills and realized patient savings remain unverified. Hospitals' remaining practical question is which disclosures and risk practices their vendors will preserve in enforceable commitments.

The rollback became smaller. Its surviving choices still deserve examination.