Help Shape the Future of Digital Health: CMS Requests Feedback to Improve Healthcare Technology
On May 16, the Centers for Medicare & Medicaid Services (CMS) and the Assistant Secretary for Technology Policy/Office of the National Coordinator (ASTP/ONC) published the Health Technology Ecosystem Request for Information (RFI). This RFI asks for public input on how CMS and ASTP/ONC can build a more efficient, secure, and patient-focused digital health infrastructure.
In this blog, we provide an overview of the RFI and key topics for provider feedback. You can submit your comments through the Federal Register by June 16, 2025 at 11:59 pm ET.
Background on the RFI
Since the 21st Century Cures Act was passed in 2016, CMS and ASTP/ONC have implemented several policies aimed at improving digital health data exchange and giving patients secure, electronic access to their health information.
Digital health includes tools like electronic health records (EHRs), mobile health apps, wearable devices, telehealth services, and data analytics that help patients and providers access, share, and use health information.
Although CMS and ASTP/ONC believe that the foundation for a “patient-centric digital health ecosystem” is in place, they recognize that there is much work to be done. Patients continue to face issues like long hold times on the phone when scheduling appointments and the need to fill out numerous paper forms.
Through this RFI, CMS and ASTP/ONC are seeking feedback from patients, providers, payers, health IT companies, and other stakeholders on how to best utilize digital technology for a better healthcare experience.
The RFI includes sections tailored to specific stakeholders (e.g., a separate section for patients vs. providers), but you are welcome to comment on any section. In this blog, we highlight the topics most relevant to providers. You can view all sections of the RFI here.
Key Areas for Provider Feedback
Below, we outline the topics CMS and ASTP/ONC are seeking feedback on from providers. You do not need to comment on every topic. Responding to just one question is enough to make your voice heard!
Digital Health Apps
- Encouraging Adoption: What can CMS do to help providers, especially in rural areas, adopt digital health tools?
- Workflow Barriers: What are the challenges in integrating digital health apps with physician workflows (e.g., quality reporting, clinical documentation, billing)?
- EHR Data Accessibility: How important is it for all data in an EHR to be easily accessible, regardless of format (e.g., scanned documents, free-text notes, structured data)? What are the challenges and costs associated with different data formats?
- Third-Party Integration: How can third-party digital products improve administrative workflows, such as auto-populating intake forms and scheduling appointments?
Data Exchange
- Current Technologies: What digital health technologies are you currently using or supporting?
- TEFCA: Do you have any feedback on the Trusted Exchange Framework and Common Agreement (TEFCA)? Feel free to share examples or suggest improvements.
- Reducing Burden: How can CMS reduce the burden of data availability and sharing for providers?
- Streamlining Data Reporting: How can CMS simplify providers’ clinical quality data responsibilities (programs such as MIPS, ASCQR, Hospital Inpatient and Outpatient Quality Reporting, etc.)? Are there requirements CMS should consider for data registries that would help make quality measurement more efficient?
Digital Identity
- Identity Credentials: How can CMS encourage providers to accept a set of universal digital identity credentials (e.g., CLEAR, ID.me, Login.gov) from partners and patients instead of having separate, proprietary logins for each provider portal? How can CMS balance convenience with patient privacy?
- Trust Communities: How can members of trust communities* (such as Qualified Health Information Networks (QHINs), which operate under TEFCA) help reduce the burden on providers while strengthening identity management?
*Trust communities are groups of organizations that agree to follow common standards, policies, and technical requirements for securely exchanging health information.
Information Blocking
- Revising Exceptions: Should ASTP/ONC revise any of the information blocking exceptions to improve the access, exchange, and use of electronic health information (EHI)?
- Disincentives: Are there additional disincentives for information blocking that ASTP/ONC should consider?
- Report Information Blocking: How can CMS encourage providers to report information blocking on the ASTP/ONC portal?
Next Steps
- Share this information with your colleagues.
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If you have any questions on this, let us know!
Written By: Sarrah Hakim, MHSA
About the Author: Sarrah is a Manager of Health Policy at Anatomy IT.
