Collaborating for Impact: Where Lantana’s Health Technology Priorities Meet Industry Vision

July 3, 2025

 Lantana responded to the CMS RFI on the Healthcare Technology Ecosystem, and we wanted to share highlights from our public response on building a resilient, innovative, and patient-centered health technology ecosystem.

Our recommendations emphasize practical, standards-based strategies, and we’re encouraged to see alignment across all public stakeholder submissions, including those from providers, payers, technologists, and patient advocates.

🔑 Shared Recommendations: National Priorities We Champion

🔗 FHIR as the Foundation for Interoperability

Lantana reaffirmed that HL7® FHIR® should continue to serve as the core infrastructure for APIs and data exchange. We called for CMS to expand use cases beyond patient access into prior authorization, price transparency, and public health.

✅ Public Comments Echoed This Strongly:

  • Astounding levels of support by commenters emphasized FHIR’s central role
  • Nearly universal support from every stakeholder category — hospitals, clinicians, and vendors alike.

🔓 Open APIs Over Proprietary Systems

We advocated for investment in open-source FHIR tooling and Software Development Kits (SDKs) to reduce implementation burden, especially for under-resourced providers.

✅ Stakeholder Consensus:

  • Public comments across sectors identified proprietary APIs as a key barrier to innovation.
  • Many emphasized the need for publicly available testing tools and infrastructure to support scalability and adoption.

🏥 Scalable Access to Population-Level Data

Lantana urged CMS to support FHIR Bulk Data APIs for cohort queries and quality measurement; both are critical for public health and value-based care.

✅ Broad Agreement:

  • Quality reporting and public health surveillance appeared as top interoperability use cases in the majority of comments.
  • CDC’s NHSNLink was repeatedly cited as a model for real-time surveillance enabled by FHIR.

🧠 AI & Computable Data Infrastructure

We highlighted how standardized, computable Electronic Health Information (EHI), through APIs, can unlock the potential of advanced analytics, AI tools, and NLP for public health and clinical support.

✅ Public Comments Aligned:

  • 71% of comments emphasized the transformative potential of AI.
  • Stakeholders across categories supported enabling AI through structured, interoperable APIs.

🧭 National Directory of FHIR Endpoints

Lantana strongly supported establishing a nationally governed, publicly accessible FHIR endpoint directory, empowered by UDAP and digital certificates.

✅ Shared Vision:

  • Hospitals, industry leaders, and state agencies supported this directory as critical for referrals, public health, and consumer access.
  • Many advocated treating it as a public utility for ecosystem-wide benefit.

📚 USCDI Expansion with Practical Guardrails

We encouraged the evolution of USCDI to include richer content (e.g., care plans, social determinants) while managing scope through tiered implementation and alignment with FHIR US Core profiles.

✅ Widespread Concern:

Most commenters praised USCDI progress but noted critical gaps in representing complex care needs and non-clinical factors and recommended its further expansion.

🤝 Where Policy and Innovation Intersect

Lantana’s submission reflects both technical pragmatism and strategic foresight, focusing on long-term infrastructure, public-private partnerships, and practical tools to empower implementers.

We’ll continue to support clients and partners in navigating this shift, delivering standards, tooling, and strategies to realize a more connected, fair healthcare system.

🌐 Looking Ahead

CMS has an opportunity to advance a future-ready health IT ecosystem that prioritizes:

  • 🧩 Open, modular, standards-based APIs
  • 🛡️ Decentralized yet secure identity and trust frameworks with additional focus on patient-centered access and empowerment
  • 📊 Scalable infrastructure for data liquidity, analytics, and quality measurement
  • 🧠 AI-ready, computable infrastructure

At Lantana, we’re proud to contribute policy-anchored, technically informed guidance to help CMS and industry partners realize this vision.

Let’s continue collaborating to build a truly connected, equitable, and intelligent health data ecosystem. 💡

Download Lantana’s Full Submission

HL7, CDA, FHIR and the FHIR [FLAME DESIGN] are the registered trademarks of Health Level Seven International and their use does not constitute endorsement by HL7.

Posted in Blog, Interoperability