I was honored to attend the June 3 CMS and ASTP/ONC Health Technology Ecosystem RFI Listening Session in Washington, D.C.—an invitation-only meeting convened by the Centers for Medicare & Medicaid Services (CMS) and the Assistant Secretary for Technology Policy (ASTP). The session brought together government leaders and a curated group of health IT stakeholders, including representatives from standards bodies, providers, developers, payers, and advocacy organizations, to discuss pressing issues raised in the recent Health Technology Ecosystem RFI.
This wasn’t your typical government meeting. It felt more like cementing a moment to make the future better and doing so through top brass commentary coupled with breakouts providing space for candid input, collaborative exploration, and real-time reactions. The day was structured around targeted breakout discussions, each focused on unpacking policy and implementation challenges that will shape the future of interoperability, digital quality, and patient-centered innovation.
Each breakout I participated in was rich with insights and hard truths we need to grapple with as an industry.
This session lived up to its name. There was consensus that while we’ve made significant progress, real-world data exchange remains messy and inconsistent. This includes accessing usable clinical data, which often requires connections far more complex than the current USCDI-based API structures anticipate, to address all provider needs, including providers ancillary to primary care. Variability in FHIR server implementations, sandbox environments, certification gaps, and data content all contribute to friction. While standards and related policy floors (with corresponding certification and enforcement programs) are key ingredients to better data quality and liquidity progress, implementation guidance and support are essential.
Participants raised familiar but unresolved issues like proprietary code sets driving up costs, identity login and app registration challenges, lingering confusion between current vs. historical data, lack of trust among trading partners, and the need for transparency alongside holistic engagement and collaboration. We also discussed the need for scalable approaches to improve data quality and governance. And once again, the idea that regulation is the only real driver to achieving scalable “technology” in healthcare came up, which was accurate and sobering.
We also touched on policy asymmetries, spanning HIPAA to HITECH to 21st Cures, and the need for reciprocal credentialing models to support broader adoption and reduce data sharing friction. Privacy and consent management was another hot-button topic, particularly the legal and regulatory patchwork across states that creates barriers to interoperable care and frustrates both patients and providers.
This session also explored foundational elements needed to modernize and sustain HIE infrastructure. Much of the discussion centered on how to align incentives for different stakeholders, especially ancillary and community-based providers, to adopt interoperable solutions.
We explored the burden of integrating disparate identity management systems and the persistent pain of patient matching failures. A key takeaway: without addressing identity and authentication gaps, even the most technically advanced APIs will fall short.
There was also discussion around the limitations of SMART on FHIR and app registration workflows, which are better than prior options but are still too fragmented. Ideas for improving certification processes to close those gaps were well received. The idea of certification for APIs over EHR or payer systems resonated.
In this breakout, we zoomed out to discuss what a functioning digital infrastructure needs to look like to support truly value-based models of care using FHIR APIs. The highly energized discussion traversed several topics. It kicked off with the importance of quality APIs, especially those supporting FHIR-based prior authorization and digital quality measurement. This includes harnessing value from ADT messages to garner actionable care coordination alongside better notifications of gaps in care through FHIR-based subscriptions.
Identity management complexities are numerous. Lack of a national identifier aside, there will be challenges in deploying and protecting digital credentials and enabling granular consent management.
More topics were touched upon, including: the limitations in current data capture practices for social determinants of health (SDOH) and more robust community connections to address patient SDOH-related needs. USCDI gaps exist for dental, and a general recognition that if you weren’t incentivized by meaningful use or other federal programs, then it's even harder to progress technological enablement to improve care coordination and offset workforce shortages.
Kudos to CMS and ASTP for not only holding the listening session but for creating a space that allowed for real back-and-forth with the experts in the room. It was energizing to meet new leaders and see so many familiar faces—people I’ve worked with over the years—bringing deep expertise and a shared commitment to making health data work better for everyone.
We have work to do. But after a day like this, I’m reminded that we’re not doing it alone and that we need to not only trust the process but be an active part of it.
If your organization is still making sense of the recent Requests for Information or figuring out how to craft a response that aligns with your strategic goals, we can help. Whether you need help interpreting what’s being asked, prioritizing what to respond to, or shaping your input to reflect your broader business objectives, our team is ready to support you. Reach out to set up a time to talk about your goals and how we can help you respond with clarity and confidence.