16 Jun The Task Force Provides Comments on the Health Technology Ecosystem Request for Information

Posted at 13:55h in Policy Communications by

The Health Care Transformation Task Force submitted comments on the Health Technology Ecosystem Request for Information (CMS-0042-NC). The Task Force’s letter focuses on the following:  

  • Patients and Caregivers:  
    • Patient Access & Education: The Task Force supports the Administration’s efforts to increase patient and caregiver engagement with digital health technologies. Digital health tools must be designed and implemented with a patient-centered approach and should be accessible and affordable to patients.  
    • Data Security & Privacy: Patients should have the ability to access their health data securely and easily. CMS should ensure that third-party technology companies comply with HIPPAA regulations.  
  • Providers:  
    • Provider Education & Engagement: CMS should provide guidance to providers around available digital health tools and how to incorporate them into their workflows. CMS and the Office of the National Coordinator for Health Information Technology should offer financial assistance to small practices that want to expand their health IT processes to assess and implement digital health technologies.  
    • Quality Measurement: CMS can simplify clinical quality data responsibilities for providers by aligning and standardizing quality measure definitions, submission formats, and timelines across both public and private payers.  
    • Interoperability: CMS should consider payment models that reward interoperability efforts and the use of standardized data exchange formats, such as Fast Healthcare Interoperability Resources (FHIR).  
    • Information Blocking: CMS should not remove providers from value-based care (VBC) arrangements as a disincentive for committing information blocking. Instead, providers should be required to submit a corrective action plan before penalties are imposed. CMS should also provide education to providers on what constitutes information blocking and how to document exceptions.  
  • Payers:  
    • Trusted Exchange Framework & Common Agreement (TEFCA): The Task Force recommends that CMS build upon and expand the role and uses of TEFCA by (1) expanding TEFCA’s permitted purposes to include health care payment and operations to incentivize adoption by payers, (2) further expanding supported use cases to include research, public health, and vital statistics, and (3) leveraging TEFCA to support data sharing between and among federal agencies and health care entities to serve multiple purposes. 
    • API Implementation: CMS should implement stronger provider-facing incentives and clear interoperability requirements to ensure that providers can consistently use and benefit from the ePA API infrastructure. 
    • Digital Identity Credentials: Digital identity credentials may reduce fragmentation if widely adopted, and CMS should promote their adoption among payers and providers.  
  • Tech Vendors, Data Providers, and Networks:  
    • Admit, Discharge, and Transfer (ADT) Notifications: Access to timely and actionable health data is essential to enable developers to build tools that support coordinated, high-quality care. ADT notifications are among the most valuable data sources to developers.  
    • FHIR: The Task Force supports CMS and ONC efforts to advance a scalable and secure FHIR endpoint directory as part of a modern interoperability infrastructure. 
    • Electronic Prior Authorization: The Task Force recommends that ONC finalize certification criteria requiring health IT developers to incorporate ePA API functionality within certified EHR systems. 
  • VBC Organizations:  
    • Supporting Innovation: CMS should preserve flexibility for VBC organizations to select tools that best align with their workflows and patient populations. Mandating specific technologies can create unnecessary complexity.  
    • Financial Incentives: CMS should implement targeted financial and operational incentives that reward measurable improvements in patient outcomes.  
    • Data Access: To fully realize the benefits of these digital tools and insights, VBC organizations must have access to comprehensive, timely, and integrated data. The Task Force supports the use of health information exchanges and other intermediaries to facilitate secure, person-centered data exchange across the ecosystem. 

Read the Letter Here