IMO Health’s clinical terminology now supports United States Core Data for Interoperability (USCDI) V3 and V4, ensuring the compliance of electronic health records (EHRs), point of care organizations, and health IT vendors with expanding regulations in 2026 and beyond.
USCDI V3 added one data class, which all EHRs and health IT systems must comply with by January 2026. However, IMO Health expanded the scope of its coverage and provided all 20 data elements added to V4, enabling customers to get ahead of interoperability requirements beyond what is required next year.
Still, many organizations underestimate the urgency, viewing non-compliance as solely a technical issue, not a significant financial, legal, and reputational risk. Organizations that fail to meet USCDI standards could face million-dollar penalties, CMS disincentives, public disclosure of violations, and more.
To understand the gravity of this change, our latest insight brief, Take compliance off the back burner: 3 risks of ignoring interoperability in 2026, outlines the most damaging consequences of delay and how clinical terminology can help mitigate them.
INSIGHT BRIEF
Want a preview? Here’s a look inside:
3 risks of non-compliance
1. Financial hits
Healthcare “actors” – providers, health IT developers, and health information networks or exchanges – found responsible for information blocking can face severe financial penalties, including:
Civil monetary penalties: Health IT companies may be fined up to $1 million per violation under the Office of Inspector General (OIG). For USCDI-related errors, costs can reach $1 million per patient when data classes are incorrectly mapped or when data is missing.
Lost revenue and market access: Health IT software that fails to maintain ONC certification or maintain federal interoperability standards can render provider customers ineligible for CMS and Medicare incentive programs and Shared Savings participation. It can also damage health systems’ reputations, as the ONC publicly discloses providers found guilty of information blocking on its website. This non-compliance makes such health IT software less marketable and harder to adopt.
Reimbursement delays and denials: Health systems that fail to adopt USCDI standards and correctly map data classes to standardized vocabularies risk delayed reimbursement and denied claims from CMS.
In the last few years, USCDI standard has rapidly evolved:
- V1 (2022) was simple and mandatory
- V2 (2021) was voluntary – many vendors assumed this trend would continue in future versions
- V3 (2026), however, is mandatory under the HTI-1 Final Rule and more than doubles the content of V1, adding new domains like social determinants of health (SDOH) and insurance details
Here’s the bottom line: V3 is not optional – and compliance expectations have doubled. Maintaining clinical data to meet regulatory and reimbursement requirements can significantly strain resources and stall innovation.
The graph above shows the number of data elements added in each version of the USCDI requirements, from v1 through v4. Compared to the last mandatory version, USCDI v1, the number of required elements nearly doubles for v3 which requires compliance by January 1st 2026.
“IMO Health is uniquely positioned to help support this ecosystem,” Andrei Naeymi-Rad, VP of Corporate Strategy, said at a recent talk. “We have always understood not only how to document appropriately for clinicians, but also how to maintain that data over time so that they can adhere to ever-evolving regulatory changes during meaningful use operations.”
To safeguard against penalties and ensure correct and complete data mapping, IMO Health added thousands of new concepts, codes, and metadata to its proprietary clinical terminology in July of 2025. It also built a new application programming interface (API) to facilitate content standardization within USCDI. These additions support patient safety and protect businesses against financial penalties, optimizing revenue.
[IMO Health has] always understood not only how to document appropriately for clinicians, but also how to maintain that data over time so that they can adhere to ever-evolving regulatory changes during meaningful use operations.
“The effort we have put into solving this challenge is massive. It’s an incredible amount of effort,” Kari Karsten, Product Manager, said. “But ultimately, that puts our customers in a position to focus on what’s most important to them.”
