Health Tech Ecosystem Categories

To unlock the full potential of a modern, patient-centered healthcare system, CMS is aligning common infrastructure with private-sector innovation across a set of clearly defined categories. These categories reflect the essential roles needed to make real-time, consented health data access work—securely, reliably, and at scale.

Each category includes specific, voluntary criteria aligned with the CMS Interoperability Framework. Together, they enable a connected ecosystem where:

• Patients can easily access and share their health information
• Providers and care teams receive the data they need at the point of care
• Apps and digital tools deliver personalized support, anytime, anywhere
• Payers support outcomes and value-based models through appropriate data exchange

The following categories outline how networks, providers, payers, and technology partners can work together to bring this vision to life—starting now.

I. CMS Aligned Networks

Objective:

Allow different types of health data sources, including health information networks and exchanges and other health technology platforms to align with CMS goals for interoperability.

CMS Aligned Networks must:

• Implement CMS Interoperability Framework criteria, including clinical and claims data as appropriate.
• Respond to patient, provider, and when appropriate, payer requests following the CMS Interoperability Framework.
• Networks that meet the CMS Interoperability Framework will be designated as CMS Aligned Networks. Networks will self-attest to meet the interoperability criteria and agree to be reviewed if suspected to not be meeting the criteria.

You must meet the FULL list of criteria to be considered in this category.

II. EHR & Providers

Objective:

Ensure that providers and EHRs actively participate in CMS Aligned Networks by making complete, timely patient data available — not just structured data, but real-world clinical documentation and encounter signals that improve care coordination.

EHRs must:

• Make electronic medical information accessible to CMS Aligned Networks, including structured data (via FHIR) and unstructured clinical documents (e.g., PDFs, JPGs, TIFs) as part of the patient record as indicated in USCDI v3.
• Provide appointment and encounter notifications to those who are subscribed to specific patient records— including outpatient visits, telehealth, emergency department, and inpatient stays — to CMS Aligned Networks within 24 hours of occurrence.

You must meet the FULL list of criteria to be considered in this category.

Providers must:

• Join CMS Aligned Networks to ensure electronic medical information is available and discoverable across care settings.
• Support patient-centered workflows that enable real-time access to electronic medical information across systems — both for treatment and patient use.
• Make electronic medical information accessible to CMS Aligned Networks, including structured data and unstructured clinical documents (e.g., notes, PDFs, JPGs, TIFs) as part of the patient record as indicated in USCDI v3 (or later).

You must meet the FULL list of criteria to be considered in this category.

III. Payers

Objective:

Join or create a CMS Aligned Network and provide claims data to CMS Aligned networks when requested by patients, providers, and, when appropriate, other payers.

Payers must:

• Make claims data accessible to CMS Aligned Networks, in alignment with Patient and Provider Access API standards.
• Respond to patient, provider, and where appropriate, payer requests.
• Implement CMS Interoperability Framework criteria, including clinical data as appropriate.

You must meet the FULL list of criteria to be considered in this category.

IV. Patient Facing Apps

Objective: 

To unlock the full potential of modern digital health, CMS is supporting a voluntary, standards-based ecosystem of private-sector technology partners - including apps, EHRs, and providers - that integrate with CMS Aligned Networks. This ecosystem is designed to deliver immediate value to patients through real-world, high-impact tools that are secure, user-centered, and connected. CMS is looking for early adopters to highlight and prove that modern technology is possible to deliver quickly. 

Patient Facing Apps must:

1. Meet the overall app criteria - Apps seeking CMS highlighting or promotion must:
   • Support data exchange with patient identity verification either via an intermediary personal health record application or using a CMS-approved service for IAL2 or equivalent (e.g., mDLs) and AAL2 (e.g., passkeys) in order to generate digital credentials that can be used to access health records from CMS Aligned Networks.
   • Enable Medicare program connectivity, whenever possible and appropriate, for users who are Medicare beneficiaries by offering a way to be notified of communications from Medicare.gov  (e.g., notices, EOBs, fraud alerts).
   • Participate in CMS review, including disclosure of data sources, terms/agreements and a basic security checklist.
   • Offer trial access for Medicare patients if the app charges a fee.
   • Participate in CMS discovery experience, allowing their app to be presented as a recommended option to eligible beneficiaries (e.g., through an “app store” interface on Medicare.gov).
   • Be implemented and operate in a manner consistent with the HIPAA Rules when provided by a HIPAA covered entity or business associate.
2. Meet one of the following initial use cases

   1. Kill the Clipboard

      Objective:
      Eliminate manual check-in forms and fragmented data collection by enabling patients to share their verified health and identity information directly with providers at the point of care - and receive their visit record back - using modern digital tools built on FHIR.

      The below criteria are meant to be visionary and to illustrate the goals of the initiative. For criteria that are less mature, early adopters will collaborate with CMS to document and publish implementation guidelines. 

      Apps:

      • Digital credentials generated through a CMS-approved service for IAL2 or equivalent (e.g., mDLs) and AAL2 (e.g., passkeys).
      • Enable patients to transmit information using FHIR, including their digital insurance card and health history (via QR code, Smart Health Card, or Smart Health Links).
      • Allow patients to retrieve a summary of their visit (e.g., notes, diagnoses, instructions) from the provider at the end of the encounter in FHIR format and then presented in a user-friendly form.
      • Must retrieve patient health records from a CMS Aligned Network using 

      EHRs:

      • Must accept patient health data from the patient-facing app via QR code, Smart Health Card or Smart Health Links using FHIR for structured data exchange at check-in.
      • Must provide patients the ability to retrieve a visit record in FHIR format via the same method used at check-in.
      • Should not require portal credentials or additional account setup to accept or return data when the patient’s identity is verified using a CMS-approved service for IAL2 or equivalent (e.g., mDLs) and AAL2 (e.g., passkeys).

   2. Conversational AI Assistants

      Objective:
      Use AI-powered assistants to deliver personalized, context-aware guidance to patients by securely accessing and interpreting their medical history in real time.

      The below criteria are meant to be visionary and to illustrate the goals of the initiative. For criteria that are less mature, early adopters will collaborate with CMS to document and publish implementation guidelines. 

      Apps:

      • Provide personalized AI-driven support across the patient’s clinical record - including symptom checking, care planning, coordination, and chronic disease support.
        • Must either connect to a CMS Aligned Network directly or via a personal health record application.
      • Responses must clearly indicate when the results are AI-generated and include appropriate disclaimers when not intended to replace clinical judgment.
      • Conversational AI tools will clearly distinguish educational content from clinical guidance, assist patients directly when appropriate and guide them to care from a health professional when needed.

   3. Diabetes & Obesity Prevention and Management

      Objective:
      Provide tailored, data-driven support to individuals at risk for or living with diabetes and obesity, powered by direct access to clinical data from trusted networks.

      The below criteria are meant to be visionary and to illustrate the goals of the initiative. For criteria that are less mature, early adopters will collaborate with CMS to document and publish implementation guidelines. 

      Apps:

      • Must connect to a CMS Aligned Network directly or via a personal health record application that has connected to a CMS Aligned Network.
      • Use the clinical record to generate personalized coaching, reminders, and risk alerts.
      • Adapt support for both prevention and active management, including medication, lab trends, and nutrition/activity tracking.
      • Must specifically provide appropriate resources for patients who are pre-Diabetic.
      • Be implemented and operate in a manner consistent with the HIPAA Rules when provided by a HIPAA covered entity or business associate.

You must meet the FULL list of criteria to be considered in this category.

V. Friend of the Ecosystem (Individuals and Organizations)

Objective:

Work alongside the pledgees to provide support, feedback, and/or technology that assists pledgees in successfully delivering on their pledge.

VI. Patient and/or Caregiver

Objective:

Use patient/caregiver-facing applications to get our health information from CMS-Aligned Networks. We pledge to provide input from a patient and caregiver perspective.