HIMSS has urged the United States Department of Health and Human Services (HHS) to remove technical barriers and economic disincentives to interoperability and information access.

HIMSS delivered its comments in response to the Centers for Medicare and Medicaid Services (CMS) and Assistant Secretary of Technology Policy (ASTP/ONC) request for information on the Health Technology Landscape. HIMSS encouraged CMS and ASTP/ONC to adopt policies that would make health information exchange and access economically self-sustaining.

The comments reinforced HIMSS’s policy principles and research on the value of digital health for Medicare beneficiaries, the rationale for information exchange, artificial intelligence, access to telehealth services, supporting public health data modernization and recommended safeguards for protecting information security, privacy and patient safety. 

HIMSS recommended the following:

• Interoperability: Remove barriers to interoperability, including economic misalignment and technical barriers. HIMSS supports integration between all interoperability approaches, entities and trusted exchange frameworks, including current standards-based approaches, cloud scale and AI-driven data harmonization when demonstrated to be effective, to reduce technical barriers to interoperability. HIMSS urges CMS and ASTP/ONC to rebalance incentives through targeted subsidies, procurement policy and AI-friendly certification so information exchange becomes both technically and economically self-sustaining.
  
• AI: Policies and regulatory frameworks should find a balance that promotes and accelerates the responsible deployment and use of safe and trusted AI tools that have a demonstrated to benefit patients, providers and other participants in the health ecosystem.Governance should ensure that AI is continually monitored and revalidated following deployment in the field. Specifically, HHS should consider the HIMSS Global Artificial Intelligence Policy Principles and HIMSS’s response to the White House Office of Science and Technology Policy Artificial Intelligence Action Plan RFI when developing a regulatory framework that considers risk and use cases for the deployment and use of AI.HHS should also monitor the growing divide between large, well-resourced health systems and small organizations, particularly those that care for at-risk and underserved communities, and ensure that the benefits of AI are available to all types of healthcare organizations.
  
• Telehealth: HHS should work with Congress to clarify reimbursement for telehealth services. The lack of certainty that telehealth services will be reimbursed at the same rate as in-person services is putting a strain on providers.
  
• Data visualization: HHS should incentivize the use of visualization and analytics tools to drive better care outcomes and performance.
  
• Digital quality measurement: HIMSS supported the intended goal of CMS to use of FHIR-enabled digital quality measures (dQMs) for all reporting programs, which provide a more meaningful and actionable measure of care quality than traditional claims-derived quality measures while reducing data collection and reporting burden. HIMSS provided specific guidance for necessary progress, particularly incorporating the USCDI+ quality domain into certified health IT functionality, nimbly addressing gaps in available FHIR-supported quality measures for specialties, long-term hospitals and skilled nursing facilities, and behavioral health, and improving incentives for health organizations to participate in real-world testing.
  
• Implement safeguards
  • Cybersecurity: CMS and ASTP/ONC should leverage the2024 HIMSS Healthcare Cybersecurity Survey Report for insights into necessary cybersecurity safeguards and HIMSS’s response to Office for Civil Rights HIPAA Security Rule proposed rule. HIMSS emphasized the importance of different approaches to make security, risk assessment and documentation requirements more scalable to the security needs of small practices and practices caring for rural and underserved communities and their business associates.
    
  • Digital literacy: Building upon HIMSS’s framework for assessing Digital Determinants of Health, CMS should require any beneficiary-facing application or AI-enabled service to demonstrate basic accessibility and clear usability.
    
  • Information exchange: CMS should move toward a policy that ties reimbursement to open, standards-based APIs (FHIR R5, SMART on FHIR), adherence to information-blocking prohibitions and transparent data-portability metrics. Such requirements support competition, facilitate beneficiary choice and prevent costly data silos.
    
• Public health involvement: CMS and ASTP/ONC should continue partnering with public health and coordinating with the Centers for Disease Control and Prevention (CDC) and state, territorial and local agencies to ensure public health data systems are modernized and public health and health care entities are exchanging critical information.