HTI-5 just told every EHR vendor: you can no longer claim a bot is not a covered user under information blocking. Autonomous AI systems are explicitly named in the rule.
The rule also deletes the condition that let vendors refuse third-party write-back requests as infeasible. That condition was the universal justification for keeping AI out of the chart.
On certification: 34 of 60 criteria proposed for removal. The model card requirements go. The C-CDA criteria go. What survives is basically a FHIR API program. New entrants save a year and six figures.
The real play here is infrastructure. Whoever builds the agent-native FHIR read-write layer with a compliant evidence log owns the default path for AI apps that need chart access. The moat is the paper trail.
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