Black Book Research national survey maps federal, state, and local mandates impacting hospital, physician, and payer information technology in 2026
WASHINGTON, DC / ACCESS Newswire / December 9, 2025 / Black Book Research today announced the release of new survey results, 2026 U.S. Healthcare Technology Regulatory Outlook: Federal, State & Local Requirements Impacting Health IT.
Issued ahead of the 2026 regulatory go-live year, the survey provides a nationwide view of laws and regulations taking effect in 2026 that directly impact healthcare information technology, software platforms, and managed services used by hospitals, physicians, and payers.
Developed as a service to the entire health information technology community including HIT vendors, current clients, prospects, and end users, the survey results and analysis are designed to help the industry better support safe, efficient healthcare delivery for patients and the U.S. healthcare consumer.
Black Book's Outlook synthesizes legislative and regulatory tracking across all 50 states and key municipalities, as well as federal rulemaking from agencies including HHS, ONC, CMS, FTC, and state attorneys general. The survey consolidates how interoperability mandates, AI regulations, consumer health-data laws, and telehealth rules at the federal, state, and local levels will drive strategic and operational decisions for health IT buyers and vendors in 2026.
"2026 is shaping up to be the most consequential year for health IT regulation since the HITECH era," said Doug Brown, founder and president of Black Book Research. "We produced these survey results as a service to HIT vendors, clients, prospects, and users so they can align their technology decisions with the needs of patients and healthcare consumers. Our Outlook gives CIOs, CISOs, CMIOs, and compliance executives a single, practical map of what's coming in federal, state, and local rules and where those rules will hit their technology stack first."
Federal 2026 Health IT Rules: What's Now on the Clock
The Black Book survey identifies 2026 as a "go-live year" for multiple landmark federal mandates that directly affect EHRs, payer platforms, and connected digital health tools. Among the most significant:
ONC HTI-1 Final Rule - USCDI v3, FHIR, Algorithm Transparency & Insights Reporting
January 1, 2026: USCDI Version 3 becomes the baseline data standard for certified health IT, requiring updates to support expanded data classes (such as SDOH, health status assessments, and enhanced demographics) using FHIR US Core 6.1.0 and updated C-CDA implementation guides. Health IT developers must implement new minimum standards for key vocabularies (e.g., SNOMED CT, LOINC, CVX) by 2026, forcing EHR and ancillary systems to complete major data-model and terminology upgrades.
2026 also marks Year 1 of the ONC "Insights Condition" reporting program, requiring qualifying certified health IT developers to collect a full calendar year of metrics on interoperability, FHIR API use, public health exchange, and app ecosystems to maintain certification.
The survey details how these requirements trigger 2026-2027 EHR roadmap changes, vendor contracting cycles, and analytics/reporting infrastructure overhauls.
CMS Interoperability & Prior Authorization Final Rule (CMS-0057-F)
Beginning January 1, 2026, impacted payers including Medicare Advantage organizations, state Medicaid agencies, CHIP programs, and QHP issuers on the Federally Facilitated Exchange must:
Meet stricter prior authorization decision timeframes (generally 72 hours for urgent requests and seven calendar days for standard requests in Medicaid/CHIP and related programs).
Provide more detailed denial rationales and retain prior authorization data for multiple years to support transparency, analytics, and auditing.
Begin operationalizing new FHIR-based APIs (Patient Access, Provider Access, Payer-to-Payer, and Prior Authorization) ahead of 2027 technical deadlines, driving 2026 investments in API gateways, clinical workflow integration, utilization management engines, and revenue cycle automation.
The Black Book survey notes that while many headlines focus on "prior auth reform," the deeper story in 2026 is the re-platforming of payer data and integration infrastructure that will cascade into provider and vendor technology decisions.
ONC / CMS Digital Quality and Decision Support Alignment
HTI-1's Decision Support Interventions (DSI) criteria replace traditional CDS certification, pushing hospitals and EHR vendors to expose more transparent, evidence-based, and AI-aware decision support capabilities.
CMS's promoting interoperability requirements rely on certified technology that meets updated HTI-1 standards, effectively binding 2026 EHR upgrade timelines to payment and quality-program participation.
Under-Reported Federal 2026 Flashpoints Highlighted in the Black Book Survey:
The survey calls out several lesser-covered issues that still have major implications for hospital, physician, and payer IT, including:
More stringent data-standards "minimums" that deprecate older code sets and USCDI versions, forcing data-warehouse, interface, and analytics teams to reconcile legacy mappings by the 2026 performance year.
New expectations that prior authorization and utilization management data become "first-class" interoperable data types, not just administrative artifacts, influencing how EHRs, care management platforms, and RCM tools are architected.
State 2026 Flashpoints: AI Governance, Consumer Health Data & Telehealth
Beyond federal mandates, Black Book's 2026 Outlook survey highlights an accelerating wave of state laws that reach deeply into health information systems, many of which have received little national coverage but carry heavy operational consequences. Among them:
Colorado Artificial Intelligence Act (SB 24-205, "CAIA") - High-Risk AI in Healthcare
Taking effect June 30, 2026, Colorado's AI Act is the first comprehensive state framework regulating "high-risk" AI systems that make consequential decisions in areas including healthcare services, insurance, and government benefits.
Developers and deployers of high-risk AI must implement risk management programs, bias-mitigation processes, documentation, impact assessments, and consumer disclosures-obligations that directly touch payer care-management engines, clinical risk-scoring models, fraud/waste/abuse analytics, and AI-infused clinical decision tools.
The survey flags CAIA as a template that HIT stakeholders ignore at their peril, because it sets a blueprint other states are already studying for AI systems that influence access to care.
Connecticut SB 1295 - Expanded CTDPA Protections Effective 2026
Amendments to the Connecticut Data Privacy Act under SB 1295, effective in 2026, expand consumer rights, tighten profiling rules, and strengthen protections for minors-changes that directly affect how health plans, provider organizations, and digital health companies deploy analytics, targeting, and algorithmic decisioning involving Connecticut residents.
The survey notes that these profiling and AI-related provisions are largely absent from national coverage, yet they may force reconfiguration of patient-engagement tools, risk-stratification engines, and marketing analytics platforms in multi-state systems.
Texas HB 1052 - Cross-Border Telehealth Coverage
Texas HB 1052 takes effect September 1, 2025, but explicitly applies new coverage obligations to health benefit plans delivered, issued, or renewed on or after January 1, 2026.
For those 2026 plan years, health benefit plans must cover telemedicine, teledentistry, and telehealth services when either the originating site or distant site is outside Texas, if the patient primarily resides in Texas and the provider is licensed in Texas and maintains a physical office in-state.
For hospitals, physician groups, and telehealth platforms, the 2026 plan-year trigger point turns cross-border telehealth coverage from a policy debate into a claims-processing and network-configuration reality, requiring payer and provider systems to correctly identify qualifying encounters and apply parity coverage.
Other 2026-Relevant State Trends Tracked in the Survey
The Black Book Outlook also catalogues:
States expanding or tightening consumer health data and sensitive-location protections, building on frameworks pioneered by Washington and Nevada and further refined in Connecticut and other jurisdictions.
Emerging state-level AI rules in healthcare, insurance, and employment that, while not always branded as "health IT" laws, directly affect workforce-management tools used by large health systems, payer underwriting engines, and clinical triage bots.
Local Ordinances: Biometric, Geofencing, and AI Rules with Enterprise IT Impact
At the municipal level, the Black Book survey tracks a growing cluster of city and county ordinances that, while often framed as general privacy or AI measures, carry significant implications for hospital, physician, and payer IT environments. These include:
Local prohibitions or restrictions on geofencing around health facilities, which limit how health systems, payers, and digital health companies can deploy location-based marketing, push notifications, and proximity-based services near hospitals, clinics, and pharmacies.
AI and automated-decision ordinances in large metropolitan areas, requiring bias audits and transparency for hiring, promotion, and other workforce decisions-directly affecting HR suites, scheduling platforms, and applicant-tracking systems used by health systems and their managed-services partners.
The Outlook connects these local rules back to practical questions for enterprise health IT buyers: Where can we safely deploy facial recognition, geolocation services, or algorithmic screening tools in 2026 and where must we re-architect our stack or geofence practices to stay within the law?
Key Findings for Hospitals, Physicians, and Payers
Among its early top-line findings, the Black Book survey concludes that:
Multi-state health systems will live inside a regulatory patchwork. Every U.S. hospital and health system operating across states will face divergent federal, state, and local AI, privacy, and telehealth rules that cannot be solved by a single national policy template.
Payers and payer-platform vendors will see prior authorization, AI, and consumer data protections converge. CMS-0057-F, state AI acts, and consumer health-data laws collectively create a new compliance frontier where utilization management algorithms, benefit designs, and member-facing tools will be scrutinized simultaneously for interoperability, bias, and privacy.
Physician groups and ambulatory networks will increasingly buy based on regulatory exposure, not just features or price. EHR, telehealth, and analytics procurement decisions in 2026 will turn on questions like: "Does this platform keep us inside the lines of Colorado's AI Act, Texas cross-border telehealth rules, and state-specific consumer health data protections?"
"Black Book polling respondents are telling us they can no longer separate technology strategy from regulatory strategy," Brown added. "We created this multi-jurisdictional survey so that vendors, providers, payers, and other HIT stakeholders can work from the same fact base, reduce federal-state-local compliance surprises, and stay focused on what matters most: improving patient outcomes and the experience of the U.S. healthcare consumer."
About the Research
The 2026 U.S. Healthcare Technology Regulatory Outlook survey and analysis synthesize:
A nationwide scan of federal, state, and major local laws and regulations with effective dates or enforceable provisions in calendar year 2026 that materially affect:
Clinical and administrative health information technology
Software platforms supporting care delivery, operations, and member services
Managed services and outsourcing contracts in hospital, physician, and payer markets
Structured interviews and surveys with health system, physician group, and payer executives, including CIOs, CMIOs, CISOs, compliance officers, and general counsel.
Independent legal and policy reviews were used to contextualize the survey responses and rank regulatory issues by impact and urgency for HIT stakeholders.
The 2026 research, survey, and its published findings were conducted by Black Book as a service to all HIT vendors, clients, prospects, and users, with the goal of helping the industry better align technology, compliance, and operations to enhance care delivery for patients and the U.S. healthcare consumer.
About Black Book Research
Black Book Research is a full-service, healthcare-centric market research and public-opinion firm and a premier provider of competitive intelligence, client experience polling, and technology rankings for the global healthcare industry. Since 2002, Black Book has provided unbiased, crowd-sourced performance data and strategic insights to hospitals, physician groups, health plans, investors, and technology vendors worldwide.
This press release and the associated survey findings are for informational purposes only and do not constitute legal advice. Organizations should consult qualified counsel for guidance on specific laws and regulations. Download complimentary industry stakeholder research and reports at https://blackbookmarketresearch.com or contact research@blackbookmarketresearch.com.
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SOURCE: Black Book Research
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