ONC COMPLIANCE
Transparency Disclosure Statement
Published in compliance with the Office of the National Coordinator for Health IT (ONC) Health IT Certification Program. Covers costs, limitations, data portability, information blocking, and exception handling for GlaceEMR and the connected Glace product suite.
Required by 45 CFR § 170.523(k)(1). Effective date: 2026-01-01. Last updated: 2026-05-22.
Published Documents
The certificate, the data export specification, and the related ONC artifacts are public PDFs hosted at our canonical document URL.
- GlaceEMR 6.0 ONC Compliance Certificate (PDF, issued 2024-06-17)
- GlaceEMR Export Data Dictionary (PDF) – specification for the (b)(10) Electronic Health Information Export.
- Real World Testing Plans: 2022, 2023, 2024 (PDF).
- Real World Testing Results: 2022 results, 2023 results (PDF). The full library is on the Real World Testing page.
- CHPL Listing for GlaceEMR (Certified Health IT Product List).
This statement is published by Glenwood Systems, LLC (the “Developer”) in compliance with 45 CFR § 170.523(k)(1) and the ONC Health IT Certification Program Conditions and Maintenance of Certification (Cures Act Final Rule).
Certified Product
Product name: GlaceEMR
Developer: Glenwood Systems, LLC
Certification edition: 2015 Edition Cures Update
Certifying body: Drummond Group LLC (ONC-ACB)
Listing: See the Certified Health IT Product List (CHPL) for the current CHPL Product ID, certified criteria, and test results.
Certification Statement
This Health IT Module is compliant with the ONC Certification Criteria for Health IT and has been certified by an ONC-ACB in accordance with the applicable certification criteria adopted by the Secretary of Health and Human Services. This certification does not represent an endorsement by the U.S. Department of Health and Human Services.
Criteria Certified
GlaceEMR is certified to the following 45 CFR § 170.315 criteria: (a)(1-5, 12, 14-15); (b)(1-3, 7-11); (c)(1-4); (d)(1-9, 11-13); (e)(1, 3); (f)(1-2, 4-5, 7); (g)(2-7, 9-10); (h)(2).
Clinical Quality Measures Certified
CMS electronic clinical quality measures tested: CMS 2v7, 22v6, 50v6, 52v6, 56v6, 65v7, 66v6, 68v7, 69v6, 74v7, 75v6, 82v5, 90v7, 117v6, 122v6, 123v6, 124v6, 125v6, 127v6, 128v6, 129v7, 130v6, 131v6, 132v6, 133v6, 134v6, 135v6, 136v7, 137v6, 138v6, 139v6, 142v6, 143v6, 144v6, 145v6, 146v6, 147v7, 149v6, 153v6, 154v6, 155v6, 156v6, 157v6, 158v6, 159v6, 160v6, 161v6, 164v6, 165v6, 166v7, 167v6, 169v6, 177v6, 347v1, 645v1.
Additional Software Used
The certified capabilities rely on the National Library of Medicine (NLM) API for terminology and value-set services.
The remainder of the Glace product suite (GlaceRCM, GlaceScribe, GlacePhoneSmart, GlaceBillSmart, GlaceGrow, GlaceOffice, GlaceIQ) is not separately certified under the ONC Health IT Certification Program. These products integrate with GlaceEMR through internal APIs and do not affect the certified functionality of GlaceEMR itself.
Costs and Fees
Glenwood Systems publishes its commercial-cost posture so prospective customers know what they will pay and what they will not.
What is free
- Implementation: $0. No setup fees for new customers.
- Data migration: $0. Migration from your prior EHR and billing platform is included.
- Initial training: $0. Role-based training (clinicians, billers, front desk) for go-live is included.
- Support: Named account-team contacts and standard support are included with all subscriptions.
Subscription pricing
GlaceEMR and the broader Glace platform are sold on a per-provider monthly subscription. Pricing varies by product selection (EMR alone, EMR + Scribe, full platform), practice size, and contract term. Specific pricing is disclosed in the Master Service Agreement at the time of contracting.
GlaceRCM billing
If you select GlaceRCM as your full-service medical billing partner, billing is a percentage of collections, with no base fees and no per-transaction billing. During contracting, a minimum monthly amount may be set. It is not an added fee; it is a floor that keeps the negotiated rate fair when a practice’s stated collection volumes turn out to be materially understated, and practices operating at the volume they represented do not reach it. The applicable percentage, and any minimum, are set out in the Master Service Agreement.
Things that cost extra
- Custom integrations beyond standard HL7 / FHIR / CCDA interfaces.
- Third-party services contracted directly by the customer (CGM vendor fees, fax services, premium SMS volume, etc.). See § 7 below.
- Custom reports beyond the 200+ included standard and visual-builder reports.
- On-site training travel (training itself is included; travel costs are pass-through).
No hidden fees
There are no data-export fees, no contract-renewal increases except as explicitly stated in the MSA, and no fees for using the certified APIs.
Limitations
Per ONC requirements, the following limitations and types of costs may affect customer use of the certified GlaceEMR product.
Interoperability constraints
- Integration with third-party systems depends on those systems supporting standard HL7, FHIR R4, CCDA, or Direct Secure Messaging interfaces.
- CareQuality participation provides nationwide health-information exchange; participation by another organization in CareQuality is required for exchange to occur with that organization.
- Hospital and lab interfaces require both endpoints to agree on message format and routing. We work with you to bring up new endpoints on request.
AI feature limitations
- AI features generate suggestions for clinician or biller review.
- All clinical decisions, all coding selections, and all billing submissions remain the responsibility of the licensed provider or authorized biller.
- AI suggestions are derived from the patient’s chart, the visit context, and trained models. They are not a substitute for professional judgment.
- AI scribe transcription (GlaceScribe) requires audible patient consent in jurisdictions that mandate two-party consent.
Operational constraints
- Certain advanced or specialty-specific configurations may require setup work that is included in implementation but may add days to go-live timelines.
- Performance of the certified APIs depends on customer network conditions and authorized application behavior.
- Patient-portal availability depends on patient self-enrollment; we do not auto-enroll patients without practice authorization.
Data Portability
Customer data belongs to the customer. We provide full data exports in standard formats, on request, at any time during or after the contract term.
Export formats
- Continuity of Care Document (CCDA): per-patient and bulk export, conforming to the C-CDA Implementation Guide.
- FHIR R4: full USCDI v3 coverage via the certified FHIR API. Bulk Data Access (Flat FHIR) supported.
- Structured CSV: for billing, scheduling, and operational data. Includes claim history, payment history, scheduling history, and patient demographics.
- Native database extracts: in coordinated transitions to another vendor, raw structured extracts are available.
Certified EHI export (b)(10)
The certified Electronic Health Information (EHI) export lets authorized users export all EHI for a single patient, a defined patient population, or every stored patient. Exports download as a ZIP archive of CSV, HTML, PDF, JPG, PNG, and XML files, extractable with standard tools. The Export Data Dictionary documents the export specification.
No barriers to portability
- No contractual barriers to data portability.
- No proprietary lock-in formats. All exports are in published, industry-standard formats.
- Export requests are fulfilled within 30 days; routine FHIR API access is always available.
Information Blocking
Glenwood Systems does not engage in information blocking as defined by the 21st Century Cures Act (42 U.S.C. § 300jj-52). We comply with all applicable patient-access requirements and provider-access requirements.
Access pathways
- Patients: access their electronic health information through the certified patient portal, mobile app, and FHIR API.
- Providers: exchange records through standard CCDA, Direct Secure Messaging, and CareQuality.
- Third-party applications: access patient data with patient authorization via the public FHIR API.
Exceptions we may invoke
Any practice or technical limitations on access, exchange, or use of electronic health information will be applied in accordance with the eight Information Blocking exceptions defined in 45 CFR Part 171:
- Preventing Harm Exception
- Privacy Exception
- Security Exception
- Infeasibility Exception
- Health IT Performance Exception
- Content and Manner Exception
- Fees Exception
- Licensing Exception
We document any exception applied to a specific access request and provide written justification on request.
API Access
GlaceEMR exposes certified FHIR R4 APIs for patient access and population-level access in compliance with ONC requirements.
- Patient FHIR API: single-patient access endpoint with USCDI v3 data elements. Patient authentication via OAuth 2.0 + OpenID Connect with SMART on FHIR.
- Population FHIR API: bulk-data access endpoint for authorized clinical-research and population-health use cases.
- API documentation: available at request; published endpoint URLs and authentication flows follow the SMART App Launch Framework.
- Developer registration: third-party developers may register apps for testing through the developer portal. Contact the address below to begin app registration.
- API uptime: 99.5% monthly target; measured continuously, reported in the annual Real World Testing publication.
Third-Party Dependencies
The certified GlaceEMR product depends on certain third-party services. These dependencies are disclosed here:
- Surescripts – e-prescribing network, medication history, and EPCS for controlled substances. Subscription fee covered in your GlaceEMR contract; no per-prescription charge.
- Id.me – identity proofing for EPCS providers. One-time provider enrollment; no per-prescription charge.
- Amazon and Deepgram – provide HIPAA-compliant AI infrastructure used by GlaceScribe ambient documentation. Fees included in GlaceScribe subscription where applicable. GlaceScribe operates on multi-vendor AI infrastructure that may also include other enterprise AI providers (Google, Anthropic, ElevenLabs).
- Lab interface vendors (Quest Diagnostics, Labcorp, BioReference, 50+ regional labs) – orders and results interfaces. No per-result fees.
- Hospital interface vendors (Mirth Connect, custom integrations) – HL7 v2 interfaces to 15+ hospital systems.
- Etactics – clearinghouse for claims and ERA processing.
Customer-contracted third-party services (CGM data feeds, premium SMS volume, optional fax services) are billed directly by those third parties; Glenwood does not mark them up.
Contact
For questions about this disclosure, to request additional information, to register a third-party application against the FHIR API, or to file a complaint about information blocking:
Email: moreinfo@glenwoodsystems.com
Phone: (888) 452-2363
Mail: Glenwood Systems, LLC · 1389 West Main Street, Suite 308 · Waterbury, CT 06708
To file an Information Blocking complaint with ONC directly, visit healthit.gov/feedback. Glenwood Systems cooperates with all ONC inquiries.
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