Arthur Souza Rodrigues

DROPLETS

AmLaw 100 Legal Intelligence — Distilled
Monday, November 2, 20262 featured2 also noted3 firms2 practice areasgrade 3–5
Quick Scan — Why It Matters
Wilson Sonsini Goodrich & RosatiHealthcare+ Expand
ONC's HTI-5 Final Rule Drops 14 Health IT Certification Criteria

ONC's HTI-5 final rule, published October 28, 2026, removes 14 criteria from the Health IT Certification Program, reshaping compliance and product roadmaps for health IT vendors, providers and payers.

On October 28, 2026, the Office of the National Coordinator for Health Information Technology published the HTI-5 final rule, scaling back the ONC Health IT Certification Program by removing 14 certification criteria and revising other parts of the framework. The available excerpt does not identify which criteria were removed or the revised provisions, so affected obligations must be confirmed against the rule text.

Why sophisticated counsel should care: certified health IT sits at the intersection of federal and state incentive programs, hospital and payer procurement, and vendor development cycles. A narrower criteria set can shorten conformance testing and release timelines for EHR and digital health vendors, while changing which attestations providers must make and which marketing claims remain supportable. It also matters for clients whose business models assume that a given certification status is durable.

…

Read the full dispatch →
SteptoeSanctions / Export Controls+ Expand
Treasury Proposes Expanded Outbound Investment Restrictions

Steptoe's international compliance team reports a U.S. Treasury proposal to expand outbound investment restrictions under the COINS Act, which could widen screening and reporting duties on U.S. persons' foreign investments.

Steptoe's international compliance team reports that the U.S. Treasury has issued a proposal to expand outbound investment restrictions under the COINS Act. The evidence available here is a single firm alert headline, so the proposal's specifics — covered jurisdictions, the technology or infrastructure sectors involved, the transaction forms caught (equity, debt, joint ventures), the mix of prohibitions versus notification requirements, and the comment deadline and any effective date — are not established and should be verified against the Federal Register notice and Treasury's own materials.

…

Read the full dispatch →
DIG DEEPER
MOST CONSEQUENTIALONC's HTI-5 Final Rule Drops 14 Health IT Certification Criteria

ONC's HTI-5 final rule, published October 28, 2026, removes 14 criteria from the Health IT Certification Program, reshaping compliance and product roadmaps for health IT vendors, providers and payers.

On October 28, 2026, the Office of the National Coordinator for Health Information Technology published the HTI-5 final rule, scaling back the ONC Health IT Certification Program by removing 14 certification criteria and revising other parts of the framework. The available excerpt does not identify which criteria were removed or the revised provisions, so affected obligations must be confirmed against the rule text.

Why sophisticated counsel should care: certified health IT sits at the intersection of federal and state incentive programs, hospital and payer procurement, and vendor development cycles. A narrower criteria set can shorten conformance testing and release timelines for EHR and digital health vendors, while changing which attestations providers must make and which marketing claims remain supportable. It also matters for clients whose business models assume that a given certification status is durable.

…

Wilson Sonsini Goodrich & RosatiHealthcare
health-it-certificationhti-5onchcehrdigital-healthderegulationhealth-it-vendors
AR
Today's Curator
Arthur Rodrigues. Corporate Counsel & Corporate Secretary at Teachable, Inc. Founder of Cicero Intelligent Minds. Former BigLaw (O'Melveny, Weil, Hughes Hubbard). JD/LLM Michigan Law. Droplets is a personal project; the views are his own, not Teachable's.
Full Analysis — The Details
01 — HEALTHCARE1
Wilson Sonsini Goodrich & Rosati+ Expand
ONC's HTI-5 Final Rule Drops 14 Health IT Certification Criteria

ONC's HTI-5 final rule, published October 28, 2026, removes 14 criteria from the Health IT Certification Program, reshaping compliance and product roadmaps for health IT vendors, providers and payers.

On October 28, 2026, the Office of the National Coordinator for Health Information Technology published the HTI-5 final rule, scaling back the ONC Health IT Certification Program by removing 14 certification criteria and revising other parts of the framework. The available excerpt does not identify which criteria were removed or the revised provisions, so affected obligations must be confirmed against the rule text.

Why sophisticated counsel should care: certified health IT sits at the intersection of federal and state incentive programs, hospital and payer procurement, and vendor development cycles. A narrower criteria set can shorten conformance testing and release timelines for EHR and digital health vendors, while changing which attestations providers must make and which marketing claims remain supportable. It also matters for clients whose business models assume that a given certification status is durable.

…

health-it-certificationhti-5onchcehrdigital-healthderegulationhealth-it-vendors
Read the full dispatch →
02 — SANCTIONS / EXPORT CONTROLS1
Steptoe+ Expand
Treasury Proposes Expanded Outbound Investment Restrictions

Steptoe's international compliance team reports a U.S. Treasury proposal to expand outbound investment restrictions under the COINS Act, which could widen screening and reporting duties on U.S. persons' foreign investments.

Steptoe's international compliance team reports that the U.S. Treasury has issued a proposal to expand outbound investment restrictions under the COINS Act. The evidence available here is a single firm alert headline, so the proposal's specifics — covered jurisdictions, the technology or infrastructure sectors involved, the transaction forms caught (equity, debt, joint ventures), the mix of prohibitions versus notification requirements, and the comment deadline and any effective date — are not established and should be verified against the Federal Register notice and Treasury's own materials.

…

outbound-investmentcoins-acttreasury-rulemakingexport-controlsnational-security-investmentcompliance-screening
Read the full dispatch →
Also noted

Grade 3 — worth a glance, not the full analysis.

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