21st Century Cures Act: EHI Export

Updated: Jun 23, 2020

This blog focuses on the 170.315(b)(10) “Electronic Health Information (EHI) Export” criterion and action items for EHR developers that kick in 6 months after publication (note that while the Final Rule has been released, it hasn’t officially been published – that date occurs when it appears in the Federal Register). A future blog will cover Information Blocking requirements for developers.




To refresh your memory, 170.315(b)(6) “Data Export” mandates that Certified EHR Technology (CEHRT) must be able to export a batch of CCDs containing data elements from the Common Clinical Dataset (CCDS) without developer assistance. A well-defined and practical requirement, not just for those migrating from one EHR to another but for a host of other uses.


Although 170.315(b)(10) EHI export replaces (b)(6), it is quite different and some elements warrant investigation:


  • On page 207, the regulation text states “the patient population EHI export capability of this criterion could require action or support on the part of the health IT developer. We acknowledged in the Proposed Rule (84 FR 7448) that because of anticipated large volume of electronic health information that could be exported under this specific proposed capability, developer action or support could be needed.” But the draft test method: