Physician-Focused Payment Model Technical Advisory Committee (PTAC)
U.S. Department of Health and Human Services
200 Independence Avenue SW
Washington, DC 20201

Submitted via email: PTAC@HHS.gov

September 5, 2025

RE: Request for Input; Using Data and Health Information Technology to Transparently Empower Consumers and Support Providers

Dear Members of the Committee:

Thank you for the opportunity to provide comments in response to the Request for Input (RFI) on Using Data and Health Information Technology to Transparently Empower Consumers and Support Providers.

Accountable for Health is a non-partisan, national advocacy and policy organization dedicated to accelerating the adoption of effective accountable care. We work to support policymakers in advancing a health care system that delivers better outcomes, improved care experiences, greater access, and lower costs. Central to effective accountable care reforms is transparent, interoperable, and patient-centered data infrastructure that empowers individuals and equips providers to deliver high-quality, coordinated care.

Using data and digital tools to empower consumers and support provider decision-making is essential to making accountable care work. Too often, people experience health care that is fragmented, duplicative, wasteful, and confusing. Accountable care reforms aim to change that by improving care experiences and outcomes through care coordination, connected care teams, and services that address both medical and non-medical needs. Accountable for Health applauds the Administration’s commitment to reducing undue burden and promoting a seamless and secure flow of health information between patients, providers, and payers, which will not only support providers currently participating in accountable care arrangements but also make value-based care more attractive to late adopters who remain in fragmented fee-for-service delivery.

As the Physician‐Focused Payment Model Technical Advisory Committee (PTAC) prepares for future discussions on the use of data and technology in APMs, we offer recommendations based on our commitment to accelerate the adoption of accountable care that improves health care for all individuals and communities. In prioritizing digital health tools, we urge the Committee to focus on opportunities that are simple and accessible for patients and caregivers. Digital technologies that are burdensome for beneficiaries to use will not be successful in supporting shared decision-making or improving outcomes.

Our responses to specific questions of the RFI are below. Additional feedback can be found in the chart in Appendix A.

1) How can electronic health vendors work together to improve data interoperability?

Electronic health vendors can improve data interoperability by collaborating to accelerate the adoption of unified industry standards such as FHIR and removing barriers that limit integration across systems. Data interoperability presents a major challenge for integration and innovation, largely due to slow and inconsistent adoption of industry standards like Fast Healthcare Interoperability Resources (FHIR). While the industry is making progress, uptake remains sluggish. The lack of interoperability and standard adoption continues to represent a critical barrier to efficient data exchange and technological advancement.

Addressing the issue requires not only better technical solutions and unified standards, but also greater collaboration and governance across organizations. Greater adoption of interoperability standards like FHIR would bring significant benefits to healthcare by enabling seamless, secure data exchange between disparate systems and organizations. With standardized data formats and protocols, healthcare providers could access complete and up-to-date patient information regardless of which EHR system is used, reducing errors and improving care coordination. Patients would benefit from a smoother experience, as their medical history could follow them effortlessly between doctors, specialists, and hospitals, empowering them to be more engaged in their own care. Additionally, standardized interoperability paves the way for innovative healthcare technologies, data analytics, and population health initiatives, ultimately leading to better patient outcomes, increased efficiency, reduced provider burden, and lower costs across the healthcare system.

2) How can data infrastructure be improved to ensure the availability of patient data?

Improving data infrastructure to ensure the availability of patient data requires building scalable, interoperable systems that support timely, reliable access to information across care settings.

To ensure the availability of patient data, accountable care entities managing clinical and financial risk must have scalable, interoperable infrastructure that supports timely, data-driven care management. Today’s healthcare infrastructure still relies heavily on on-premises EHRs, which often face limitations in computing power and connectivity. Improving data availability requires advancing interoperability across systems and shifting toward modern infrastructure capable of supporting real-time data exchange.

Alternative Payment Model (APM) participants need shared operational transactions that allow for the timely exchange of clinical and claims data (both adjudicated and preadjudicated), real-time prior authorizations (including those associated with CMS waivers (e.g., SNF 3-Day Waiver)), and real-time checks on current performance to date (e.g. the use of Da Vinci Value-Based Performance Reporting Implementation Guide) instead of performance at a quarterly or yearly basis. Access to real-time admission, discharge, and transfer (ADT) data across the care continuum is also critical to managing aligned beneficiaries proactively.

Modernizing HIPAA transactions and adopting modern computing approaches such as API-based data exchange will be key to building the infrastructure needed to ensure patient data is available when and where it is needed.

4) What funding mechanisms can be used to promote improvements in patient data?

Funding mechanisms to promote improvements in patient data should include financial incentives for Advanced Alternative Payment Model (APM) participants to adopt and use technologies that reduce readmissions and improve outcomes. Today, Accountable for Health members invest in technology to improve patient experience and outcomes, such as utilizing a patient navigator in nursing facilities to improve post-acute care, but receive no support or incentives to make such investments beyond the nature of two-sided risk arrangements.

A stable environment for payment models, paired with flexibility in permitted technologies, is essential for the success of APM participants. These organizations should have access to incentives and/or subsidies to support adoption (e.g., preferential quality scoring/benchmark treatment for demonstrating active use of certified digital tools or allowing ACOs to use prepaid shared savings for digital health adoption investment). ACOs also face issues with beneficiaries opting out of data sharing, as it is challenging to effectively manage patient care with limited claims history. We encourage PTAC to consider ways to either require data sharing as a condition of participation or exclude those beneficiaries from certain programs to hold ACOs harmless.

10) What are the most effective approaches for empowering patients with multiple chronic diseases to help improve quality, outcomes, and TCOC?

One effective approach for empowering patients with multiple chronic conditions is to establish a nationwide provider directory of FHIR endpoints that supports seamless data access and coordination across care teams. Accountable for Health members currently spend significant time and resources mapping providers and specialties to ensure that they are managing their patients’ care throughout their care journey. A nationwide provider directory would allow access to the right data for the right entity, at the right time; reduce time to market; improve patient quality of care; and create an ecosystem for the next generation of health care technology.

This resource would enable faster and more accurate retrieval of patients’ medical histories and insurance records, which is crucial for care coordination, transitions of care, and minimizing duplicate tests or procedures. Additionally, clarity about where claims data resides—and how to access it through FHIR APIs—would support more effective analytics, eligibility verification, and value-based care initiatives.

11) What are effective care delivery models to increase the engagement of patients with chronic conditions?

One effective care delivery model to increase the engagement of patients with chronic conditions is the use of real-time event notifications to alert providers when their patients experience an acute episode. Event notifications play a central role in enabling established care teams to respond quickly, coordinate follow-up care, and prevent avoidable complications or readmissions. In some cases, ACOs are able to work with hospitals to obtain event notifications for a roster of aligned patients. In other cases, hospitals are unwilling to work with the ACO entity itself and/or accept a roster for notifications. Event notification transmissions should be required in near real-time to enable timely care coordination.

Policies that could be helpful to clear barriers to consistent implementation of the event notification Condition of Participation (CoP) include:

  • Requiring hospitals to enable roster-based approaches for notifications
  • Requiring any hospital receiving reimbursement under any risk-bearing program (e.g., Medicare Advantage, MSSP, ACO REACH) to participate in electronic patient event notifications to community providers
  • Eliminating the ability for EHRs to control what they are willing to contribute
  • Further development of ADT messaging standards to support inclusion of new data elements and types of notifications, such as facility name, address, and NPI; consideration of a FHIR API transaction and existing implementation guides (e.g., Da Vinci Unsolicited Notifications), which also reduces burden related to ACO waivers
  • Expansion of the patient population to whom the CoP applies to include patients discharged from the ED without admission, as well as those admitted in observational status
  • Expansion of the minimum information in the notification to include the discharge disposition data field, offering more detail about the recommended outpatient care

Conclusion

Accountable for Health appreciates the opportunity to provide comments on this RFI. If you have any questions about our comments or need more information, please do not hesitate to contact Mara McDermott, mmcdermott@accountableforhealth.org.

Sincerely,

Mara McDermott signature

Mara McDermott
CEO
Accountable for Health

QUESTIONFEEDBACK/OPPORTUNITIES
How can electronic health vendors work together to improve data interoperability?Access to real-time, comprehensive information that can travel with patients between appointments/providers that is easily accessible; shift towards digital processes away from paper- and fax-based methods; leverage FHIR-based standards to ensure seamless and consistent data exchange (including use of industry-wide, national initiatives like TEFCA); EHR modules should also allow for easy integration of third-party applications that promote innovation and enhance functionality across systems.
How can data infrastructure be improved to ensure the availability of patient data?Cloud-based solutions that allow scalable, secure, and transportable data storage (while maintaining robust privacy and security practices); develop and deploy robust health information exchanges at regional and national levels; enable investments in health data analytics capabilities to derive actionable insights from patient data.
What are solutions to transferring data from mobile and wearable apps into EHRs and vice versa?Utilize FHIR-based APIs for seamless data transfer between devices/applications and EHRs, including standardized data fields to minimize churn and friction; patient-directed data sharing mechanisms; ensure validation processes for accuracy and reliability of patient-generated health data.
What funding mechanisms can be used to promote improvements in patient data?Previously, APM bonuses served as a mechanism to fund these types of improvements and investments. Today, those bonuses lag substantially. Congress should revisit this structure with CMS input as to how to incent improvements in patient data.
How can patients be empowered to: (a) better understand the health care data they can access through tools such as patient portals (e.g., to make data meaningful and actionable). (b) make better decisions regarding their health?Make health data meaningful and actionable: Prioritizing user-friendly design in EHRs and ensure patients are not inundated with medical jargon or uncomprehensible recommendations. Embedding personalized insights and tailored recommendations that transforms raw data into actionable guidance. EHRs should not just be data repositories but rather dynamic tools that support value-based, person-centered care. Empowering patients to make better health decisions: patient portals to integrated shared decision-making tools; embedding risk calculators or predictive models to provide patients and clear understanding of potential outcomes; access to personalized health coaching. Secure messaging features to enable real-time communication with care teams.
How can patient outcomes (e.g., quality, patient experience, clinical outcomes, total cost of care) be improved by empowering patients through the use of health data and digital health tools?Predictive analytics and remote monitoring allows for real-time oversight of patient progress. Visibility into comprehensive data sets in real-time enables personalized care plains tailored to meet patient needs. Use of AI to augment care team for low-complexity, non-clinical needs.
What are effective approaches for using patient navigators to support patients in managing their health care?Answer
QuestionCare team training in communication and shared decision-making enhances ability to foster trust and collaboration throughout the care journey. Patient-reported outcomes integrated into decision-making process with structured follow-up protocols that allows for adaptability in care plans.
What are best practices for encouraging shared decision‐making between clinicians and patients? and What role can health system level incentives and organizational culture play in influencing shared decision-making?Aligning financial incentives with shared decision-making; developing performance-based metrics to track patient engagement and empowerment; cultivating a culture that values collaboration and trust. Recognizing and awarding clinicians and care team members who excel in patient engagement alongside deployment of a shared decision-making model as the baseline expectation.
How can providers help to engage patients and promote patient empowerment?Access to complete health records/test results and provide personalized educational materials for patients and caregivers. Encourage patients to set and track health goals.
What are the most effective approaches for empowering patients with multiple chronic diseases to help improve quality, outcomes, and TCOC?Human-centered, digital-forward approach that meets patients where and when they most need support. Tools need to be easy to use, convenient and accessible. Enabling access to digital-forward tools such as remote monitoring devices and telehealth alongside peer support and mentoring groups.
What are effective care delivery models to increase the engagement of patients with chronic conditions?Team-based care models that go beyond the traditionAL doctor-patient relationship and include a multidisciplinary set of stakeholders. This enables trust to be built with the care team and support for navigating a complex and burdensome healthcare ecosystem. Effective delivery models also leverage digital support tools, including patient apps or portals, to actively manage their condition through tracking of health data and real-time communication with care team members. VBC models should also incentivize long-term patient engagement rather than episodic care.
What role can ancillary providers (e.g., nurses, nutritionists, community health workers, pharmacists, behavioral health providers) play in promoting shared decision‐making and patient empowerment?Ancillary providers are an extension of the core medical team and help to create a collaborate care team. This could include stakeholders such as a pharmacist or nutritionist. Shared decision-making model enables all members of the care team to be equipped with data and resources to engage patients effectively and proactively.
How can patients with chronic diseases be empowered to make healthy choices about nutrition and other factors that affect their health?Personalized nutrition and lifestyle coaching to identify strategies that promote healthy behaviors; access to remote monitoring tools to track key health metrics; partnerships with community-based organizations to address SDOH.
What kinds of benefit design changes can help to incentivize patient empowerment?Zero-dollar copays for primary care services, reduced cost-sharing for patients who actively manage their health, rewards for meeting health goals or joining wellness programs, and coverage of digital health and remote monitoring tools.
How can payment and performance measurement for population based, total cost of care models such as ACOs be designed to incentivize patient empowerment?Payment and performance measures should integrate patient engagement and activation metrics, patient-reported outcomes, and use of shared decision-making tools into quality metrics. In turn, shared savings and related financial incentives will further reward ACO investment.
How can providers be incentivized to promote patient empowerment (e.g., through the use of digital tools, patient education)?Today, APM participants are severely hampered in their ability to talk to patients about the benefits of accountable care. Freeing providers up from these restrictions and allowing more open communication would improve overall patient education and more collaborative care conversations.
How can patients be incentivized to participate in value‐based care?Dedicated care teams; zero-dollar or reduced out-of-pocket costs for choosing high-value providers; financial rewards for participating in care management programs; wellness programs that reward healthy behaviors and action on preventive care.

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