Not-So-Hidden Gems in the 21st Century Cures Act Final Rule: Get to Know the Conditions of Certification

Steven Posnack | December 15, 2022

Don’t get me wrong, the information blocking regulations are important, but let’s not forget that the 21st Century Cures Act (Cures Act) and our implementing regulations (Cures Act Final Rule) had a few other impactful provisions. In particular, certain changes to the ONC Health IT Certification Program may seem like “more of the same” for health IT developers, but in reality they are really important and beneficial to clinicians, researchers, and the public alike.

Two new education resources are now available specifically geared toward these audiences to describe “what the rule says” and what those regulatory requirements “mean” from the perspective of those who interact with developers of certified health IT and use their products. These resources are simplified, paraphrased descriptions of two of the Cures Act Final Rule’s Conditions of Certification to help orient, inform, and activate. They include the “Communications” and application programming interface (“API”) Conditions of Certification.

Clinical users should know that developers of certified API technology are required under the API Condition of Certification to follow specific business practices. For instance, you can engage with whomever you want regarding the use of certified API technology without needing to first seek the developer’s permission. Similarly, third-party app developers – did you know that under the API Condition of Certification, developers of certified API technology are required to publish (among other transparency requirements) a full disclosure of the fees that would apply to the use of certified API technology?

Along those same lines, the Communications Condition of Certification specifically covers the types of communications that can be made about certified health IT, such as disclosing screenshots and video. This Condition of Certification set limits on the ways in which developers of certified health IT could restrict how you communicate certain information about their certified product(s).

The two new “Explained!” resources can be found on ONC’s Health IT Certification Program’s resources page and, as always, if you have questions regarding information blocking, please check out