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Client Alert

CMS Seeks Healthcare Industry Input on Future of Digital Health

June 9, 2025
Comments on the RFI, due by June 16, present a rare opportunity to shape future technology standards, reporting requirements, and business opportunities.

Healthcare stakeholders have a critical opportunity to shape the future of digital health technology in Medicare. Providers, payers, technology companies, life sciences organizations, and all other stakeholders are invited to provide public comments on the digital health ecosystems used in the Medicare market in response to a Request for Information (RFI) from the Centers for Medicare & Medicaid Services (CMS) and the Assistant Secretary for Technology Policy/Office of the National Coordinator for Health Information Technology (ASTP/ONC). Comments are due by June 16, 2025.

Understanding the RFI

On May 13, 2025, CMS, in partnership with ASTP/ONC, published an RFI seeking to understand common pain points and areas for improvement in the digital health ecosystem, particularly as it relates to secure electronic access to personal health information for Medicare beneficiaries. The RFI is relevant to healthcare providers, payers, technology companies, and life sciences organizations because CMS and ASTP/ONC are seeking input on how to improve secure access to health data, simplify digital identity requirements, reduce administrative burdens, and promote the adoption of innovative digital health tools.

Efforts to make health information more interoperable, support value-based care, and ensure that digital solutions are accessible and user-friendly for Medicare beneficiaries could lead to new technology standards, reporting requirements, and business opportunities

The agencies are particularly interested in making health information more interoperable, supporting value-based care, and ensuring that digital solutions are accessible and user-friendly for Medicare beneficiaries. These efforts could lead to new technology standards, reporting requirements, and business opportunities across the healthcare sector.

The RFI is part of a broader push by CMS and ASTP/ONC toward increasing the flow of health information among patients, providers, and payers via “smartphone applications and other modern tools.”

Key Areas for Comment

Key areas that CMS and ASTP/ONC are seeking comment on include:

  • Interoperability and ease of information sharing between different health data storage systems
  • Encouraging the use of uniform digital identity credentials instead of different “proprietary logins” that patients need to manage for each health data storage system (e.g., different patient portals for each provider)
  • The impact of and areas of improvement for existing digital health APIs like CMS’s Blue Button 2.0 and other Fast Healthcare Interoperability Resources (FHIR)-based APIs
  • Mitigating the burden of technology requirements on providers and payers
  • Increasing patient, provider, and payer engagement with digital health products

CMS Remarks

CMS hosted an in-person listening session on June 3, 2025, to discuss the RFI with healthcare stakeholders. CMS noted that the RFI reflected its modernization agenda to “accelerate digital health innovation, strengthen data security, enhance program integrity, and drive operational efficiencies” within Medicare and Medicaid. Alongside the discussion, CMS announced plans to modernize digital health infrastructure by developing a national provider directory, modernizing identity verification for Medicare.gov, expanding the Blue Button 2.0 API, making the Data at the Point of Care tool widely available, and further advancing trusted data exchange efforts.

Deadline and Submission Requirements

  • Deadline: June 16, 2025
  • File Code Reference: CMS-0042-NC
  • Method: Electronic submission preferred at regulations.gov
  • Suggestion: Annotate comments with question labels (e.g., “PR-1”)

The RFI represents a rare opportunity to directly influence federal policy on healthcare technology. Organizations that engage now may help shape regulations that affect the industry for years to come.

The authors would like to thank Amritha Ramalingam and Sabrina Li Shen for their contribution to this Client Alert.

Endnotes

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