On May 16, 2025, the Centers for Medicare & Medicaid Services (CMS) published in the Federal Register a request for information (RFI) to gather public feedback on the landscape of digital health products available to Medicare beneficiaries and the overall state of data interoperability and health technology infrastructure. Here’s an overview of that RFI:
What is the Health Technology Ecosystem RFI?
The CMS RFI on the Health Technology Ecosystem is a joint effort by CMS and the Assistant Secretary for Technology Policy/Office of the National Coordinator for Health Information Technology (ASTP/ONC) to gather public input on improving technology to empower Medicare beneficiaries.
What is the goal of the RFI?
The central goal of the RFI is to advance a seamless, secure, and patient-centered digital health infrastructure. This infrastructure aims to leverage modern technology to help seniors and their families take control of their health and well-being, manage chronic conditions, and access care more efficiently. CMS aims to shape a future that delivers digital tools to seniors and families so they can make informed choices, manage health conditions, and stay healthy.
Who can provide input?
The RFI invites input from many stakeholders, including patients, caregivers, providers, payers, and technology developers. It seeks feedback on how CMS and ASTP/ONC can:
- Drive the development and adoption of digital health management and care navigation applications.
- Strengthen interoperability and secure access to health data through open, standards-based technologies.
- Identify barriers preventing the seamless exchange of health information across systems.
- Reduce administrative burden while accelerating progress toward value-based, patient-centered care.
What’s the history of the health technology ecosystem?
The initiative builds upon efforts like Blue Button 2.0 and the CMS Interoperability and Patient Access Final Rule. The RFI aims to ensure that health information is not locked away in silos but flows securely to empower patients and providers.
While the building blocks for this ecosystem are in place through initiatives like the 21st Century Cures Act and related rules promoting patient access to digital data, CMS and ASTP/ONC recognize that the current experience for patients, caregivers, and providers is neither seamless nor simple. Challenges remain, such as patients needing multiple accounts for different providers and difficulty leveraging health records in digital products.
The RFI explicitly addresses the transition to value-based care (VBC), highlighting technology’s critical role in this transformation. It seeks feedback on aligning technology requirements, including certified electronic health record technology (CEHRT), with the needs of providers in VBC programs (Alternative Payment Models – APMs) to reduce burden and support adoption.
Are there specific areas for which CMS seeks information?
Specific areas of inquiry within the RFI include:
- Patients and Caregivers: Needs for health management/care navigation apps, accessing health information in one location, awareness of existing apps, missing features, what CMS can do to encourage interest, desired data access, the role of Trusted Exchange Framework and Common Agreement (TEFCA) and health information exchanges (HIE), valuable operational use cases, information blocking, and digital identity.
- Providers: Leveraging digital health products, obstacles to development/utilization of apps for workflows, accessibility of data regardless of format, improvements for administrative workflows via apps, current use of Fast Healthcare Interoperability Resources (FHIR) APIs, the role of TEFCA, strategies for data sharing, simplifying quality data responsibilities, and digital identity.
- Payers: Policy/technical limitations of TEFCA, accelerating API implementation, accepting digital identity credentials, value of a nationwide provider directory, simplifying clinical quality data responsibilities for providers, and information blocking.
- Technology Vendors, Data Providers, and Networks: Steps to stimulate developer interest, valuable additional CMS data, digital identity implementation challenges/benefits, encouraging use of open APIs, nationwide provider directory of FHIR endpoints, unique TEFCA functions and alternatives, United States Core Data for Interoperability (USCDI) effectiveness and limitations, effective certification criteria, redefining certification, facilitating access to full EHI, network connections and bulk FHIR, point-to-point vs. network infrastructure, ensuring network viability, information blocking examples, and price transparency shortcomings.
- Value-Based Care Organizations: Incentives/obstacles for leveraging digital health products, integrating themes like AI/population health/care coordination into APM requirements, essential health IT capabilities and data types for VBC, how certification supports VBC, needed certification criteria, reducing complexity in technology requirements, supplementing certified electronic health record (EHR) technology (CEHRT) requirements, different requirements for APM organizations, flexibility for Advanced APMs, interoperability challenges in VBC, standardization, and digital identity/provider directory benefits for VBC.
What’s the reaction to the RFI?
Some perceive this RFI as a significant evolution in federal policy, signaling an intent to deepen government influence over digital health infrastructure and innovation pathways. Some view the RFI as inviting the technology market into a dialogue about regulatory shaping. It may indicate to incumbent vendors that their participation in transforming Medicare’s digital layer is not optional.
What’s next?
The public comment period for the RFI is open through June 16. CMS will use input from this RFI to develop future regulatory and subregulatory policy proposals and guidance. The government may also use information from this RFI to plan programs and design infrastructure.
Certifi’s health insurance premium billing and payment solutions help healthcare payers improve member satisfaction while reducing administrative costs.
