In recently submitted public comments, HIMSS emphasized that true digital health transformation requires addressing underlying economic imbalances and technical readiness of the healthcare ecosystem.

Regarding the Health Data, Technology, and Interoperability: ASTP/ONC Deregulatory Actions To Unleash Prosperity (HTI-5) proposed rule, HIMSS stated support for the goal of streamlining certification and modernizing data exchange in a letter to the Assistant Secretary for Technology Policy (ASTP).

Addressing the Economic Burden of Interoperability

HIMSS notes that while federal policy has successfully expanded expectations for data accessibility, these requirements have placed a significant strain on hospitals and developers. The growth of health data is transforming these entities into "de facto cloud data management companies," a role they are not structurally or financially equipped to handle.

• Misaligned Incentives: Providers currently bear the technical and economic burden of enabling exchange, while the commercial value often accrues to downstream technology firms.
• AI and Infrastructure Costs: Allowing autonomous AI agents to initiate information requests could exponentially increase infrastructure costs for hospitals tasked with validating these requests.
• Sustainable Funding: HIMSS advocates for a framework where the costs of information access are more equitably distributed, ensuring that "special effort" requirements do not lead to unlimited, uncompensated third-party workflows.

Strategic Transition to API-Enabled Access

HIMSS strongly endorses the transition from outdated Consolidated Clinical Document Architecture (C-CDA) standards to FHIR-based APIs, which allow for real-time, modular data exchange. However, the society warns that a "one-size-fits-all" timeline could leave critical sectors behind.

• Public Health Readiness: HIMSS noted that many public health agencies still rely heavily on C-CDA for essential functions like electronic case reporting (eCR). HIMSS estimates that state and local agencies require a $36.7 billion investment over the next decade to successfully transition to modern API-enabled infrastructure. HIMSS believes developers will continue to support C-CDA infrastructure for their customers, even if C-CDA is not required for certification.
• Implementation Timelines: To ensure market stability, HIMSS recommends a two-year window of voluntary compliance for any new certification requirements or mandated advancements to the USCDI baseline.
• Regulatory Alignment: HIMSS urges the ASTP to coordinate closely with CMS to ensure that removing certification criteria aligns with the removal of corresponding provider-required actions in programs like MIPS and Promoting Interoperability.

HIMSS remains committed to collaborating with the ASTP and HHS to refine these proposals, ensuring they reduce regulatory burden without compromising clinical workflows or patient safety.