This study aims to propose a novel gap analysis framework that can be used to identify any problems in Cloud Health Information Systems projects. Advance implementation of cloud computing to improve Health Information Systems needs a comprehensive gap analysis methodology considering many aspects associated with the technology. The new gap analysis is derived from two widely used methodologies namely ITPOSMO and ServQUAL. The way to integrate both techniques is discussed along with how it could be easily applied by evaluators of Cloud Health Information Systems projects.