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When it comes to interoperability, we must talk in specifics

Thoughts on the recent CMS listening session

Dan Wilson: 06.17.2025 3:59 PM
Clinical Data ExchangeRegulation Update

Interoperability remains a buzzword. After years of collective progress working towards the right data, right place, right time objective, it’s time to acknowledge that interoperability is more a philosophy in health tech than a word that means something specific.

Recently I had the opportunity to participate in the CMS’s Health Technology Ecosystem RFI Listening Session—an opportunity I am grateful for. There were many familiar faces from the data exchange and interoperability community in attendance. These are people who care deeply about solving the challenges facing our healthcare system, and there’s a general consensus among them that something real has to be done to fix a system in crisis.

The thought that weighed heavy on my mind as I left the session, however, was this: If after so many years of shared effort we still struggle to agree on a well-defined set of priorities, how do we focus enough of our collective resources on delivering the outcomes that will turn interoperability from a buzzword into a system-altering reality? Our approach needs to evolve.

To bring the ecosystem along, we need to get specific when talking about the problems we’re trying to solve and why they’re worth addressing.

This is where our market-based system, paired with focused roadblock clearing from our federal leaders, can deliver real results.

Interoperability is a means to an end. To bring the ecosystem along, we need to get specific when talking about the problems we’re trying to solve and why they’re worth addressing.

Clarity will drive progress

Didn’t we get specific at the session, you ask? While CMS spoke about building a national provider directory, modernizing identity verification, expanding the data-at-point-of-care pilot, and strengthening the trusted data exchange infrastructure, the opportunity remains for greater clarity on the specific problems we’re trying to solve with each commitment. If we want to effect real change, but lack specificity, progress will remain limited.

Take the focus on enhancing the provider directory, for example. Is it about improved credentialing, network management, record location, or something broader?

We all agree record location needs improvement. Yet, when expanding on the problem for different stakeholders—a patient saying “I just want all my records,” a payer asking for “the records that go along with this claim,” and a provider reviewing “outside records relevant to today’s visit,”—the complexity of the problem comes into focus.

This narrow example can be further expanded: The payer doesn’t just need visits for payment decisions, they also need records for a new member, data to prepare a quote, charts for risk adjustable encounters during a timeframe, records to close a specific quality gap, context from an ordering provider to support utilization management at the performing provider, and so much more. This same breakdown can be done for provider and patient needs— to say nothing of the non-HIPAA covered entities looking for records.

A vibrant ecosystem is actively working on solutions for our current-day challenges and will eagerly use an improved provider directory to advance what’s possible. This can become an ideal public/private collaboration through a delicate balance of base capabilities from CMS and tailored market solutions from private industry. If we don’t define why each effort matters and instead layer in prescriptive technical requirements, the market will continue to make suboptimal investment decisions. We’ll continue to focus on incremental improvements and solutions that don’t solve core industry issues; rather, ones that strictly address the regulatory requirements.

While these things may seem too specific compared to CMS’s promise to strengthen the trusted data exchange infrastructure, we need to start with focused steps that address very specific problems to move us towards a future where right data, right place, right time is a reality.

Sharing our perspective to help shape the future

There was a sense of excitement at the CMS listening session and perhaps even a feeling of “this time will be different.” In order to build on the momentum generated by the listening session, we (all of us invested in interoperability) need to get a win fast so we can continue to bring people along to solve our more thorny problems. We can’t just talk about interoperability, we need to show stakeholders that we can actually solve problems that matter to them and their work.

We must focus narrowly in the short term so we can build confidence in the market that when we say we can solve something, we will. With TEFCA, for example: Let’s figure out how we get providers and EHRs that aren’t currently participating in any national exchange to be connected. Or, from a patient access perspective: How can we solve the authentication, record location, and access problem for patients so it becomes very straightforward for them to get their data loaded into a product of their choice without needing to remember logins to every single portal?

While these things may seem too specific compared to CMS’s promise to strengthen the trusted data exchange infrastructure, we need to start with focused steps that address very specific problems to move us towards a future where right data, right place, right time is a reality.

In addition to getting more specific about what they are trying to solve and why, I look forward to CMS articulating how any new policies drive rapid solution delivery. To CMS’s credit, this effort isn’t happening in a bubble. As stakeholders invested in moving our ecosystem forward, it’s on us to provide clear input on what policies need to evolve so meaningful solutions flourish.

I commend CMS for inviting public input on how to improve interoperability, data exchange, and reduce the administrative burden in healthcare, among other things. At Moxe, we are driven by a similar purpose: to improve complex, outdated, and costly processes. We’re fundamentally changing the way clinical data is shared, connecting payers and providers with the highest quality, most efficient clinical data. Our perspective on payer-provider interoperability is grounded in experience. We hope our responses to CMS’s Request for Information share practical insight into what it takes to make meaningful progress, improve collaboration, and facilitate smarter interoperability.

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