Are ONC-Authorized Certification Bodies (ONC-ACBs) required to perform gap certification under the ONC HIT Certification Program?

No. We stated in the Permanent Certification Program final rule (76 FR 1291) that gap certification would be an option for ONC-ACBs and that it would be left to the discretion of each ONC-ACB as to whether to offer gap certification. We emphasize, however, that if an ONC-ACB decides to offer gap certification, it must conduct gap certification according to regulatory requirements and should be aware of ONC guidance under the ONC HIT Certification Program. ONC-ACBs should also offer gap certification according to procedures that are available to any EHR technology developer that would seek certification from the ONC-ACB and provide clear and equitable treatment of EHR technology developers’ requests for gap certification.