HTI-1 decision support interventions transparency
HTI-1 decision support interventions (DSI) transparency refers to the ONC certification criterion at 45 CFR 170.315(b)(11), adopted in the HTI-1 final rule, that requires certified EHRs to support predictive and evidence-based decision support and give users access to "source attributes" describing how each intervention was built, validated, and maintained.
What HTI-1 requires
The HTI-1 final rule (Health Data, Technology, and Interoperability: Certification Program Updates, Algorithm Transparency, and Information Sharing) was published on January 9, 2024 (89 FR 1192). It replaced the older clinical decision support criterion with the DSI criterion and defined a Predictive DSI as "technology that supports decision-making based on algorithms or models that derive relationships from training data and then produce an output that results in prediction, classification, recommendation, evaluation, or analysis."
Key requirements for developers of certified health IT, per ONC's DSI fact sheet:
- Source attributes. Certified modules must support 13 source attributes for evidence-based DSIs and 31 for Predictive DSIs. These cover items such as intended use and population, cautioned out-of-scope uses, development and input features, fairness approach, external validation, performance measures, and ongoing maintenance.
- Intervention risk management. Developers must apply risk management practices to the Predictive DSIs they supply, covering risk analysis, risk mitigation, and governance.
- Scope. Developers are responsible only for the Predictive DSIs they supply as part of their certified health IT. Health systems that add their own or third-party predictive tools can use the EHR's functionality to record source attributes for them.
- Dates. Developers had to deliver updated technology by December 31, 2024. From January 1, 2025, the DSI criterion became the one required for the Base EHR definition.
ONC described the source attributes as a baseline that helps organizations judge whether predictive tools are fair, appropriate, valid, effective, and safe (FAVES).
The HTI-5 proposal
On December 29, 2025, ASTP/ONC published a proposed rule titled Health Data, Technology, and Interoperability: ASTP/ONC Deregulatory Actions To Unleash Prosperity (90 FR 60970), which CMS refers to as the HTI-5 proposed rule. Comments closed on February 27, 2026.
For the DSI criterion, the proposal would:
- remove the requirements in 170.315(b)(11)(iv) and (v) on source attribute support, access, and modification
- remove the intervention risk management requirements in (b)(11)(vi)
- narrow the predictive DSI data requirements to fewer USCDI data classes
- remove references tied to other criteria proposed for removal
ONC summarized this as reducing the DSI criterion's scope "to fully remove the artificial intelligence (AI) 'model card' requirements," citing burden and Executive Order 14179.
Status. It is a proposal only. In its FY 2027 hospital inpatient final rule, published August 4, 2026, CMS stated that "the HTI-5 final rule will be issued after this final rule is published." We found no HTI-5 final rule in the Federal Register as of September 27, 2026. Until a final rule takes effect, the HTI-1 DSI requirements remain in force.
How Skovos handles this
Skovos does not replace EHR source attributes. Its agent registry can hold equivalent transparency fields for AI agents, such as intended use, owner, data sources, and validation notes, whatever the outcome of HTI-5.
Frequently asked questions
Does HTI-1 apply to hospitals or to EHR vendors?
It applies directly to developers of certified health IT. Hospitals feel it indirectly because their certified EHRs must expose the source attribute functionality.
How many source attributes does HTI-1 require?
Thirteen for evidence-based DSIs and 31 for Predictive DSIs.
Has HTI-5 removed the AI model card requirements?
Not as of September 27, 2026. HTI-5 was proposed in December 2025, and no final rule had been published.
Related reading
Sources
- ONC, HTI-1 final rule, 89 FR 1192, January 9, 2024: https://www.federalregister.gov/documents/2024/01/09/2023-28857/health-data-technology-and-interoperability-certification-program-updates-algorithm-transparency-and
- ONC, HTI-1 Decision Support Interventions fact sheet: https://www.healthit.gov/sites/default/files/page/2023-12/HTI-1_DSI_fact%20sheet_508.pdf
- ASTP/ONC, HTI-5 proposed rule, 90 FR 60970, December 29, 2025: https://www.federalregister.gov/documents/2025/12/29/2025-23896/health-data-technology-and-interoperability-astponc-deregulatory-actions-to-unleash-prosperity
- CMS, FY 2027 IPPS/LTCH PPS final rule, August 4, 2026: https://www.federalregister.gov/documents/2026/08/04/2026-15833/medicare-program-hospital-inpatient-prospective-payment-systems-for-acute-care-hospitals-ipps-and