The Centers for Medicare & Medicaid Services (CMS), Assistant Secretary for Technology Policy (ASTP)/Office of the National Coordinator for Health Information Technology (ONC) (collectively, ASTP/ONC), Department of Health and Human Services (HHS) issued a RFI on the Health Technology Ecosystem. Comment period ended on June 16, 2025.
SUMMARY: Effective and responsible adoption of technology can empower patients to make better decisions for their health and well-being. This request for information (RFI) seeks input from the public regarding the market of digital health products for Medicare beneficiaries as well as the state of data interoperability and broader health technology infrastructure. Responses to this RFI may be used to inform CMS and ASTP/ONC efforts to lead infrastructure progress to cultivate this market, increasing beneficiary access to effective digital capabilities needed to make informed health decisions, and increasing data availability for all stakeholders contributing to health outcomes.
AHIMA
AHIMA is a global nonprofit association of health information (HI) professionals, with over 67,000 members and more than 100,000 credentials worldwide. The AHIMA mission of empowering people to impact health® drives our members and credentialed HI professionals to ensure that health information is accurate, complete, available and trusted – enabling quality care for patients everywhere. Leaders within AHIMA work at the intersection of healthcare, technology, and business, occupying data integrity and information privacy job functions worldwide.
Read their comments and recommendations on select questions within the RFI.
American College of Physicians
June 13, 2025 – The American College of Physicians (ACP) is pleased to share their comments on the ASTP/ONC Request for Information (RFI) regarding the Health Technology Ecosystem. ACP is the largest medical specialty organization and the second-largest physician group in the United States. ACP members include 161,000 internal medicine physicians, related subspecialists, and medical students. Internal medicine physicians are specialists who apply scientific knowledge and clinical expertise to the diagnosis, treatment, and compassionate care of adults across the spectrum from health to complex illness.
ACP believes the health technology ecosystem should facilitate an environment that promotes access to timely care and quality treatment for patients while reducing administrative burden and supporting physicians in their ability to deliver innovative care. All changes to the existing network must be thoroughly vetted, and the implementation must be fully explored. Potential changes must be carefully developed, with direct, measurable impacts on clinical workflow, to ensure that innovations truly reduce the burden on physicians and their staff.
ACP appreciates the opportunity to offer our feedback and looks forward to continuing to collaborate with CMS and ASTP/ONC to implement policies that support and improve the practice of internal medicine.
Read the full commentary here.
American Hospital Association
June 16, 2025 – On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to provide comment on the ASTP/ONC’s Request for Information (RFI) regarding the Health Technology Ecosystem.
We support the agencies’ goals of reducing barriers for data interoperability and fostering innovation to support better health outcomes. The AHA recognizes the pivotal role that health technology plays in care delivery today and its potential to transform the patient and provider experience in the future. From artificial intelligence (AI) to mobile apps, medical devices to electronic health records (EHRs) — technology supports improvements in quality and efficiency for patients, caregivers and providers. Moreover, we believe that technology and data interoperability have the potential to address some of the prevalent challenges confronting the health care ecosystem today, including provider burnout and staffing shortages driven by administrative burdens. We also recognize that the innovative applications of health information technology (IT) must be balanced with reasonable guardrails to protect sensitive patient data and ensure security and privacy. In addition, while health technology can make care more efficient, implementing new tools and standards often requires significant financial investment and workflow changes for health care providers. This makes it critical for policymakers to ensure that policy changes intended to spur adoption are scoped and paced sustainably.
The AHA has several recommendations to improve health IT standards and infrastructure, increase beneficiary access to effective digital health tools, and advance data availability to improve health outcomes.
Read the full commentary here.
AMIA
June 16, 2025 – AMIA urges CMS and ASTP/ONC to advance patient-centered innovation by ensuring comprehensive, computable access to health data through standardized API and integration of patient voices in standards development. Recommendations emphasize digital identity, usability for older adults, and reducing documentation burden. AMIA calls for scalable, interoperable tools, robust privacy protections, and infrastructure that supports equitable access, innovation, and real-world testing—aligned with the 21st Century Cures Act and value-based care goals.
Read the full commentary here.
CHIME
June 16, 2025 – The College of Healthcare Information Management Executives (CHIME) appreciates the opportunity to comment on the ASTP/ONC’s request for information (RFI) on the Health Technology Ecosystem.
CHIME’s feedback addresses the questions outlined in this RFI, which seeks input from the public regarding the market of digital health products for Medicare beneficiaries, as well as the state of data interoperability and broader health technology infrastructure.
CHIME members have made substantial, ongoing investments in health information technology (IT) systems aligned with the statutory objectives of the 21st Century Cures Act and its implementing regulations – including the Office of the National Coordinator for Health Information Technology’s Cures Act Final Rule, the CMS Interoperability Rules as well as the Health Data, Technology, and Interoperability (HTI-1 and HTI-2) Final Rules., Additionally, we have made substantial, ongoing investments in privacy and cybersecurity infrastructure to ensure compliance with the Health Insurance Portability and Accountability Act (HIPAA) and its implementing regulations. These efforts reflect a deep commitment to promoting data privacy, secure health information exchange, and patient empowerment through greater access to and control over their health information.
As noted in the RFI, CMS and ASTP/ONC would like to continue to build on the existing policy framework to drive large-scale adoption of health management and care navigation applications, reduce barriers to data access and exchange, realize the potential of recent innovations in healthcare that promote better health outcomes, and accelerate progress towards a patient-centric learning health system.
CHIME members appreciate the opportunity to contribute to this important dialogue; we commend CMS and ASTP/ONC for seeking stakeholder input to guide infrastructure advancements that will expand equitable access to digital health tools, empower beneficiaries in their care decisions, and enhance data-driven collaboration across the healthcare continuum. CHIME has and continues to be a staunch champion when it comes to the need for the use of technology standards aimed at facilitating better patient care.
Read the full commentary here.
CommonWell Health Alliance
June 16, 2025 — CommonWell Health Alliance was pleased to submit comments in response to the ONC/ASTP’s Request for Information (RFI) on the Health Technology Ecosystem. As a long-standing advocate for nationwide interoperability and a Designated QHIN under TEFCA, we support ONC’s and ASTP’s efforts to strengthen the ecosystem through aligned policy, technical standards, and infrastructure.
We commend the agencies for inviting input from stakeholders across the health IT landscape and appreciate the opportunity to share insights drawn from our experience building and operating a nationwide network at scale. Our feedback emphasizes the importance of trust frameworks, real-world use case adoption, and flexible approaches that meet providers, payers, and patients where they are.
We look forward to continuing to engage with ONC, ASTP, and the broader community to advance a more connected, equitable, and efficient health care system.
Read the full commentary here.
HIMSS
June 16, 2025 – HIMSS has urged the United States Department of Health and Human Services (HHS) to remove technical barriers and economic disincentives to interoperability and information access.
HIMSS delivered its comments in response to the CASTP/ONC’S request for information on the Health Technology Landscape. HIMSS encouraged CMS and ASTP/ONC to adopt policies that would make health information exchange and access economically self-sustaining.
The comments reinforced HIMSS’s policy principles and research on the value of digital health for Medicare beneficiaries, the rationale for information exchange, artificial intelligence, access to telehealth services, supporting public health data modernization and recommended safeguards for protecting information security, privacy and patient safety.
Read the full commentary here.
MGMA
June 16, 2025 – On behalf of our medical group practices, the Medical Group Management Association (MGMA) appreciate CMS and the ASTP/ONC for taking bold steps to advance the health information technology (IT) landscape. The health technology ecosystem has progressed significantly in recent years, and we look forward to building upon existing frameworks to advance interoperability in ways that reduce administrative burden for medical groups. With a membership of more than 60,000 medical practice administrators, executives, and leaders, MGMA represents more than 15,000 medical group practices ranging from small private medical practices to large national health systems representing more than 350,000 physicians. MGMA’s diverse membership uniquely situates us to offer the following perspectives.
MGMA supports CMS and ASTP/ONC’s proactive approach to collecting stakeholder feedback on the health technology ecosystem. Health IT is critical for medical groups and provides the opportunity to improve patient care and reduce administrative burden. MGMA strongly supports the development of federal standards that promote innovation and interoperability while setting guardrails to ensure the safety of patient data. Medical groups today face a myriad of challenges such as low reimbursement, increased administrative burdens, and staffing shortages that make maintaining a practice increasingly difficult. We believe there is an opportunity for health IT to have a meaningful impact on patient care while streamlining processes for physicians and practices. However, careful consideration must be taken during the design and implementation of new technologies and regulations to ensure changing standards and requirements do not create more complications or result in costs being passed down to medical groups. Changing health IT systems should not create new hurdles that take physicians and administrators away patients.
Read the full commentary here.
NACDS
June 16, 2025 – The National Association of Chain Drug Stores (NACDS) appreciates the opportunity to comment on the request for information issued by the ASTP/ONC regarding strategies to build a more modern, resilient, and patient-centered health technology ecosystem.
NACDS endorses the objectives set forth by CMS and ASTP/ONC to cultivate a health ecosystem that puts patients at the forefront. It is critical that this initiative diminish barriers to health data access and exchange to improve care and yield better health outcomes. Furthermore, we agree that although HHS has instituted a policy framework to facilitate the seamless and secure flow of health information among patients, providers, and payers, there remains considerable potential to refine and streamline our healthcare ecosystem. One essential, and overdue improvement is the meaningful inclusion of pharmacies in the nation’s healthcare data infrastructure.
Read the full commentary here.
National Health Council
June 16, 2025 – The National Health Council (NHC) appreciates this opportunity to respond to the ASTP/ONC’s Request for Information (RFI) on the Health Technology Ecosystem.
Created by and for patient organizations over 100 years ago, the NHC brings diverse organizations together to forge consensus and drive patient-centered health policy. We promote increased access to affordable, high-value, equitable, and sustainable health care. Made up of more than 180 national health-related organizations and businesses, the NHC’s core membership includes the nation’s leading patient organizations. Other members include health-related associations and nonprofit organizations including the provider, research, and family caregiver communities; and businesses and organizations representing biopharmaceuticals, devices, diagnostics, generics, and payers.
As a unified voice for people with chronic diseases and disabilities, the NHC supports the federal government’s continued efforts to build a patient-centric, digitally enabled health care ecosystem. We commend CMS and ONC for using this RFI to examine how federal infrastructure can evolve to support accessible, secure, and interoperable digital health products for Medicare beneficiaries, with particular attention to innovation, accessibility, and real-world implementation.
Digital health tools hold tremendous promise to empower patients, improve access to care, streamline administrative functions, and reduce disparities. However, the ecosystem must be designed in collaboration with those it seeks to serve. This includes consideration of digital literacy, internet access, health literacy, and existing structural inequities. It also includes acknowledgement of the evolving landscape of patient needs, especially for individuals living with multiple chronic conditions, disabilities, and complex care coordination challenges.
Read the full commentary here.
Premier
June 13, 2025 – Premier submitted comments on a request for information issued by the ASTP/ONC and CMS to solicit input on how best to advance a seamless, secure and patient-centered digital health infrastructure. In its comments, Premier provided detailed recommendations on how CMS and ASTP/ONC can:
- Harmonize interoperability regulations to promote greater market competition;
- Update meaningful use criteria, certification standards for health IT and the overall federally-driven interoperability incentive structure to ensure that data usability for quality and process improvement are adequately incentivized;
- Clearly define information blocking and implement and enforce more stringent information blocking penalties on health data ecosystem participants beyond providers and provider organizations;
- Extend interoperable electronic health record incentives to post-acute and continuum of care providers;
- Develop a holistic framework of both financial and non-financial incentives to promote value-based care participation, which in turn results in greater adoption of tech-enabled solutions;
- Mandate a patient-directed data sharing mechanism such as Blue Button 2.0 in certified electronic health record technology (CEHRT) criteria;
- Require more standardized data sharing by CMS-regulated health plans to providers and patients; and
- Improve Risk Adjustment Data Validation (RADV) audit processes by piloting a program that relies on CMS-approved, real-time self-audit technology rather than perpetuating a pay-and-chase model.
Read the full commentary here.
Wedi
June 24, 2025 – The ASTP/ONC issued a request for information (RFI) seeking input from the public regarding the digital health environment, leveraging technology to improve Medicare beneficiary access to data, as well as the current state of data interoperability. On May 28th, WEDI conducted a Member Position event (MPA) to discuss the RFI and prepare a response.
With over 100 individuals in attendance at the MPA, representing over 30 WEDI member organizations, WEDI collected and presented comments to the RFI. The MPA facilitators included: Merri-Lee Stine (Aetna, a CVS Company, WEDI Board Chair); Denny Brennan (MHDC, WEDI Board Chair-Elect); Gail Kocher (BCBSA, WEDI Board Director); Heather McComas (AMA; WEDI Board Director); Michelle Barry (Availity; Co-Chair, Provider Information SWG); Stanley Nachimson (Nachimson Advisors; Co-Chair, Claims SWG, No Surprises Act TG); Samantha Burch (AHIP); Jeff Coughlin (AMA); Alix Goss (Point of Care Partners); Michael Phillips (CAQH); and moderator Nancy Spector (WEDI). The RFI’s emphasis on patient empowerment and effective data exchange aligns with WEDI’s mission on the use of health IT to efficiently improve health information exchange, enhance care quality, and reduce costs.
In our letter, WEDI argued that to successfully meet the goals laid out in the bipartisan 21st Century Cures Act—and to carry out the CMS Interoperability and Prior Authorization Final Rule—it’s critical that all the right players have access to the tools and capabilities they need. For payers and providers, that means efficiently sharing clinical data that helps drive better care, reduced burden, and lowered costs. For patients, technology can facilitate easy and secure access to their health information-essential to having them be fully engaged in the care process.
Read the full commentary here.