Level-setting: What the Pledge Program Is—and Isn’t

When the Centers for Medicare and Medicaid (CMS) unveiled the Health Tech Ecosystem pledge initiatives, the announcement generated plenty of buzz and excitement from many corners of the health IT world—alongside some doubt and skepticism from others. Now, just a couple of weeks later, the initial headlines have faded, but to what degree is the real work underway? And really, how much work has already been done? The industry has worked towards many of these goals for years.

So, maybe it isn’t surprising that over 60 companies signed on: 21 networks, 11 providers, and 7 EHRs committed to interoperability goals, while 30 others pledged to advance real-world health outcomes with technology. You can read more in CMS’s press release on the Health Tech Ecosystem pledge and the Becker’s article on providers pledging to “Kill the Clipboard”.

The initiative consists of 4 categories, which are aimed at modernizing health data sharing and empowering patients through digital tools.

Health Tech Ecosystem Categories

For supporters, the pledge represents a patient-first, industry-forward leap toward better data liquidity, innovation and competition. Skeptics question scope, follow-through and whether it’s more optics than operational change. Consider:

• This is not a regulation. There are no federal mandates, fines or deadlines. While there is a target date for the first quarter of 2026, this isn’t a formal compliance deadline. Failure to deliver won’t trigger traditional consequences—though the PR damage could sting should pledgers fail to deliver on promises.
• At its core, it’s a pledge to use a technical network to make data flow using specific CMS Network Criteria. Without robust, aligned networks in place, the promise risks being more aspiration than action.
• The intention is to spur innovation, increase healthy competition and make patient access to their own health data seamless—but one might ask, What are the next steps and processes to further define success metrics? While some have reported that workgroups exist for each category and that pledge organizations are having regular communications with the administration, we haven’t seen any external communication about planned public meetings to report progress or gain public input on the work. Some are worried this could evolve into a fragmented “wild west” instead of a coordinated push toward interoperability or a select group of organizations making big decisions that impact the rest of the industry without oversight.
• Could this lead to future rulemaking by CMS? If the joint government–industry pledge does not achieve its intended impact, additional rulemaking could be introduced to accelerate progress. While the outcome is uncertain, if the industry prefers informal collaboration with the government over regulation, it will be important to demonstrate measurable results from these pledges and communicate clear success metrics along the way.

Is This Pledge Unprecedented—or Just Déjà Vu?

If the whole thing feels familiar, it’s because to some degree it is. To us, this echoes earlier interoperability pushes under the Bush and Obama administrations, focused on patient rights and access to health data. As we noted in one of our CEO's Monday Musings posts, the goals remain the same but sometimes need to be called something different. As the Civitas Networks for Health analysis points out: the momentum is worth capturing.

What sets this effort apart is the scale of public commitment and the range of players signing on. Optimists see a rallying moment; skeptics recall how promising starts have fizzled before. The encouraging difference now is that executive leadership clearly had to be involved before companies signed. Having worked inside some of these organizations, we know how rare that level of buy-in has been in past efforts—and how powerful it is when executives set priorities that cascade through the enterprise.

What's Curious About This Pledge?

Even those who support the pledge have noted some quirks:

• The pledge isn’t just for health plans—but it’s CMS, not ASTP, leading the charge. It includes health systems, EHR vendors, payers, networks, and patient app developers. While Tom Keane, the ASTP, was in attendance and one of the speakers at the pledge meeting, this is still billed as a CMS initiative.
• The missing voices: Though patient access technology companies were involved, there were no patient advocacy groups included in the pledge launch. Although some patients were present and noted, the initiative is touted to have patients as the central focus of the pledge.
• Industry government collab vs regs: HHS, ASTP released HTI-4 just days after the pledge, fueling confusion. Some attendees believed the pledge signaled fewer regulations, yet the timing suggests the pledge could be groundwork for future rulemaking, ideally through cross-agency coordinated policy.
• The rollout was fast: from a request for Information (RFI) in May to development of a new CMS framework in June to pledge in July 2025. Quick momentum can inspire confidence — or caution, depending on your perspective – but it’s consistent with this Administration’s modus operandi (MO). Healthcare technology hasn’t historically moved quickly, but this could signal that, within a new CMS framework, faster progress is possible.

What Pledge Organizations Need to Do Next

1. Invite patient voices. Involve patients from the start to better understand their challenges and needs.
2. Keep end-users and workflows in mind. Seek input from end-users early—before solutions are built—so tools align with real-world needs and workflows, rather than testing and adjusting too late in the process.
3. Understand and build towards the CMS Framework: Criteria and required standards for participation in the CMS Network. Target date for some aspects of the pledge is early 2026
4. Be transparent. Share measurable outcomes—networks connected, data flows enabled, patient experiences improved—and report progress publicly.
5. Coordinate across the ecosystem. Lean on collaborative bodies like ANSI, Civitas, HL7, and  HL7 Accelerators like FHIR at Scale Taskforce (FAST) & the Da Vinci Project to align on standards and avoid duplicative or proprietary silos.

What Non-Pledging Organizations Should Expect

• Competition is heating up. Pledgers will likely gain reputational and partnership advantages, and others will need to match or exceed their efforts.
• It’s not too late to join. The door is open for new pledge organizations to participate. The pledge is broader than Medicare/Medicaid, and CMS’s Early Adopters page includes instructions on how to join. 

Key Watchpoints

Final Thoughts

The pledges are this administration’s attempt to generate momentum toward the goal of improving healthcare in the United States at a lower cost. Enthusiasm is warranted but so is care and planning.

For the Health IT community, the challenge is to turn this from a high-profile promise into coordinated, transparent, and measurable action. If the buzz can be matched with tangible results, CMS’s “Make Health Tech Great Again” movement and “Kill the Clipboard” policy and roadmap could be remembered as a turning point.

If your organization is weighing what this could mean for your competitive position—or wondering whether joining a pledge aligns with your strategic goals, Point-of-Care Partners can help. Our team has deep experience guiding health plans, providers, health tech vendors, and other stakeholders through the intersection of policy, standards, and market dynamics. We can help you assess potential impacts, anticipate what comes next, and chart the best course forward. Contact us to start the conversation.