Disclaimer: The views and opinions expressed here and on the linked collaborative sites are my own and do not necessarily represent the views or positions of Microsoft.

CMS and ASTP/ONC have released a significant Request for Information on the “Health Technology Ecosystem” (Document 2025-08701). The full document is published on the Federal Register. The deadline for comments is June 16, 2025.

This isn’t a niche request! The RFI has something for everyone involved in health technology. Whether you’re a health application developer building the next generation of tools, a patient innovator or patient advocate fighting for better access and control, a clinician or researcher on the front lines, a payer navigating new models, or an organization focused on Value-Based Care, CMS and ONC are specifically asking for your perspective. They’re seeking practical insights on interoperability, digital tools, provider burden, digital identity, and information blocking – all critical areas where diverse expertise is needed.

A Collaborative Approach to a Stronger Response

Responding comprehensively to such a broad set of questions is a significant undertaking. I’m coordinating an open effort to draft and share recommendations, structured around the RFI’s questions:

Live Web App: https://joshuamandel.com/cms-rfi-collab

GitHub Repo: https://github.com/jmandel/cms-rfi-collab

The value proposition for collaborating in this open way is straightforward:

• Rapidly Develop Themes and Granular Points: By pooling expertise, we can quickly identify key themes and develop specific, well-reasoned recommendations for each of the RFI’s questions. The repository uses individual Markdown files for each point, making it easy to contribute and iterate.
• Shared Language and Concepts: This process allows us to refine language and articulate core concepts that multiple stakeholders might find useful for their own, independent submissions. The goal isn’t a single, unified response, but a rich set of ideas that strengthen the overall input to CMS and ONC.
• Scaffolding on RFI Structure: The collaborative work is directly mapped to the RFI’s structure, ensuring that developed points are relevant and address the specific questions posed by the agencies.

Transparency and Open Discussion

Working this way means our developing ideas are public. While this transparency allows others to see and potentially anticipate or formulate counter-arguments to these recommendations, I believe this open approach is ultimately beneficial. It fosters a more transparent discussion about the future of the health technology ecosystem and allows for a broader vetting of ideas. The aim is to contribute to a more informed and robust policymaking process.

Key areas of focus for this collaborative effort include:

• Mandating and verifying API performance (Patient Access, Bulk Data).
• Transforming EHI Export into a practical, API-driven mechanism for complete record access.
• Operationalizing “without special effort” for data exchange.
• Establishing trusted digital identity and authorization frameworks.
• Enabling permissionless innovation for patient-facing applications.

An Open Invitation

If you are a health app developer, patient innovator, patient advocate, informaticist, or work in this domain:

1. Review the RFI.
2. Explore the collaborative response site and GitHub repository.
3. Contribute your insights to help shape these recommendations.
4. Borrow language, craft, and submit your own RFI Response!

Let’s provide CMS and ONC with clear, technically sound, and actionable input.