The following is a guest article by Nick Barger, PharmD, Vice President, Product at DrFirst. This article is the next in the Healthcare Regulatory Talk series.
After cruising for the first half of the year, new regulations are shifting things into high gear with a final rule that makes electronic health record (EHR) vendors responsible for integrating real-time prescription benefit (RTPB) checks and electronic prior authorization (ePA) directly into physician workflows.
Health Data, Technology, and Interoperability (HTI-4), announced July 31, 2025, is a noteworthy pivot—from voluntary to mandatory.
Assistant Secretary for Technology Policy/Office of the National Coordinator (ASTP/ONC) officials say the rule will speed access to care, touting the potential savings of millions of hours in clinician time and billions of dollars in labor costs over 10 years.
But before any of that can happen, EHR vendors are accountable for compliance and must be ready for what’s around the bend.
Real-Time Prescription Benefit Certification
HTI-4 requires EHRs to support providers in their prescription decision-making by allowing them to compare drug prices and see out-of-pocket costs in real time. This is in alignment with the existing Centers for Medicare & Medicaid Services (CMS) rule for Medicare Part D payers.
Crucial implementation notes:
- RTPB is included in the Base EHR definition starting January 1, 2028.
- Any system with electronic prescribing must include this feature.
Key takeaway: This nice-to-have feature for EHRs will now be mandatory for the first time.
Electronic Prior Authorization: Pharmacy
Updated e-prescribing certification requirements make ePA mandatory. The new rule uses APIs based on the Fast Healthcare Interoperability Resources (FHIR) standard, which uses the National Council for Prescription Drug Programs (NCPDP) SCRIPT standard version 2023011.
Here’s the transition timeline:
- Now through December 31, 2027: Developers can use the old or new standard.
- January 1, 2028, and beyond: Only the new standard is accepted.
Key takeaway: You may think you have e-prescribing covered, but building electronic prior authorization into your platform will likely be a bigger lift for your developers than expected.
Electronic Prior Authorization: Medical
In HTI-4, medical prior authorization is added into the mix for the first time. It might sound similar to pharmacy PA workflows, but medical PA workflows are vastly different and have so many variables that automation becomes complicated.
Pharmacy ePA has been around for over a decade, and DrFirst was an early innovator. However, ePA for services, procedures, and certain specialty drugs covered by medical benefits is less mature industry-wide. Our acquisition of Myndshft last year will mean a big leap forward in unifying both types of electronic prior authorization into one platform. (We’ll share more on that in a future article.)
Key takeaway: If your e-prescribing partner doesn’t have PA solutions for both medical and pharmacy benefits, it’s time to begin building your own or start shopping around.
What HTI-4 Means for Your EHR
Meeting the required updates to e-prescribing standards while juggling multiple compliance deadlines will be a massive undertaking.
Here’s what to keep in mind when reconstructing your roadmap:
- The e-prescribing transition period includes the runway needed for development and certification as well as time for implementation—and for good reason, because you are going to need that much time.
- For the real-time prescription benefit criterion, it becomes part of the Base EHR definition in 2028, and it is not optional if you want to maintain certification for electronic prescribing.
- The electronic prior authorization update represents a significant shift toward API-based workflows. So, if you haven’t already invested in FHIR capabilities, it’s time to make that a priority.
The Bottom Line
HTI-4’s requirement for EHRs aligns with the industry’s movement toward more automated, efficient healthcare workflows that benefit patients and providers alike.
This final rule is effective October 1, 2025, and the investment needed to meet these requirements will be daunting for many companies. EHR vendors must carefully consider whether to tackle the necessary updates in-house or outsource them to a trusted partner.
While developers have transition periods to work with, roadmaps fill quickly and putting off this work could create a logjam. And it’s not enough to get certified by the deadline. The new functionality must be implemented and in use by providers.
Whether you decide to build or buy, the race is on—so put the pedal to the metal on your compliance timeline.
Interested in partnering with a trusted platform vendor to meet new e-prescribing standards and comply with regulatory updates to prior authorization processes? Reach out to speak with one of our experts here.
About Nick Barger, PharmD
Nick is Vice President of Product at DrFirst, where he leads design and development of intelligent medication management solutions for the e-prescribing pioneer and the 300 EHRs and health information systems they partner with, providing clinical, regulatory, and digital workflow solutions that make healthcare more efficient and effective. Check out all the articles in the Healthcare Regulatory Talk series.
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