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.

Additional Use Case (Optional): Electronic Prior Authorization

Networks may:

• Support interoperable workflows aligned with HL7 FHIR Da Vinci standards, including the exchange of authorization requests, status updates, decision outcomes, and standardized denial reason codes.
• Facilitate auditability and transparency across the prior authorization lifecycle by maintaining records of Electronic Prior Authorization transaction events and supporting timely coordination among payers, providers, and delegated entities.

Additional Use Case (Optional): Bulk FHIR

Networks may:

• Support asynchronous Bulk FHIR export workflows for payer, provider, research, and CMS-aligned use cases.
• Demonstrate operationally usable performance at realistic scale and participate in transparent performance measurement.

Additional Use Case (Optional): Pharmacy

Networks may:

• Support bidirectional pharmacy connectivity so medication dispense data, fill status, immunizations, and medication history flow across care settings.
• Route patient and treatment queries to and from pharmacies and pharmacy systems.

II. EHRs

Objective:

Ensure that 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.

Additional Use Case (Optional): Electronic Prior Authorization

EHRs must:

• Implement FHIR-based prior authorization capabilities conformant with HL7 FHIR Da Vinci standards
• Enable real-time submission, documentation exchange, and status tracking
• Support ordering workflows associated with medical prior authorization

Additional Use Case (Optional): Bulk FHIR

EHRs may:

• Support asynchronous Bulk FHIR export workflows for payer, provider, research, and CMS-aligned use cases.
• Demonstrate operationally usable performance at realistic scale and participate in transparent performance measurement.

Additional Use Case (Optional): Clinical Trial Matching

EHRs may:

• Support EHR-based trial matching that integrates the ClinicalTrials.gov API and computable protocol standards (CDISC USDM, HL7 FHIR, ICH M11 ceSHarP).
• Surface population-level trial eligibility signals to treating providers within clinical workflows, never directly to patients.

Additional Use Case (Optional): Modern Scheduling

EHRs may:

• Make appointment discovery, booking, and management available in real time through open, standardized FHIR APIs using the Schedule, Slot, and Appointment resources, whether powered directly by the source systvem or by a cloud-based FHIR data store.
• Expose accurate, current scheduling data, including real-time availability, so patient-facing applications can present bookable slots without stale or placeholder inventory.
• Support write-back of real-time booking, rescheduling, and cancellation initiated from patient-facing applications, without requiring portal credentials or additional account setup.

Additional Use Case (Optional): Pharmacy

EHRs may:

• Incorporate pharmacy-sourced data, including medication dispense data, fill status, immunizations, and medication history, into the patient record.
• Support bidirectional exchange with pharmacies and pharmacy systems through CMS Aligned Networks.

III. Providers and their delegated technology

Objective:

Ensure that providers actively participate in CMS Aligned Networks so electronic medical information is available and discoverable across care settings.

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.

Additional Use Case (Optional): Electronic Prior Authorization

Providers may:

• Submit and manage prior authorization requests electronically within clinical workflows
• Reduce reliance on fax, portals, and other manual processes

Additional Use Case (Optional): Bulk FHIR

Providers may:

• Support asynchronous Bulk FHIR export workflows for payer, provider, research, and CMS-aligned use cases.
• Demonstrate operationally usable performance at realistic scale and participate in transparent performance measurement.

Additional Use Case (Optional): Modern Scheduling

Providers may:

• Make appointment discovery, booking, and management available in real time through open, standardized FHIR APIs using the Schedule, Slot, and Appointment resources.
• Support real-time booking, rescheduling, and cancellation so patients can schedule through apps without portal or phone dependency.

Additional Use Case (Optional): Clinical Trial Matching

Providers may:

• Receive population-level trial eligibility signals through compliant, claims-informed channels and use them to discuss relevant clinical trials with patients.

Additional Use Case (Optional): Real-Time Benefits

Providers may:

• Check patient-specific cost and coverage information in real time at the point of prescribing or ordering, across both prescription and medical benefits, using standardized APIs including the Consumer Real-Time Pharmacy Benefit Check (RTPBC) FHIR IG.
• Use real-time benefit information to discuss expected out-of-pocket costs and clinically appropriate lower-cost alternatives with patients before services are delivered.
• Verify coverage and plan status electronically at check-in and before ordering, reducing reliance on portals, call centers, and manual workflows and reducing avoidable denials.

Provider Add-On (Optional): Pharmacies & Pharmacy Systems

Objective:

Ensure pharmacies function as interoperable care nodes within CMS Aligned Networks, with medication data flowing bidirectionally across care settings and medication workflows that are closed-loop, network-based, and real-time.

Pharmacies and pharmacy systems must:

• Connect to a CMS Aligned Network in a bidirectional relationship, participating as first-class interoperable care providers.
• Respond to patient and treatment queries with medication dispense data, fill status, immunizations, and medication history.
• Contribute pharmacist-identified medication issues and adherence signals to the care team.
• Support "Kill the Clipboard" workflows so patients no longer act as the integration layer between systems.

Provider Add-On (Optional): Access Provider

Objective:

Expand patient access to technology-supported chronic care so every eligible patient has the opportunity to benefit from evidence-based, technology-enabled care that complements traditional clinical practice.

Providers must:

• Identify appropriate patients for technology-supported care and offer them technology-supported options, such as ACCESS organizations.
• Use interoperable, standards-based workflows to coordinate technology-supported care.
• Incorporate electronic care updates into clinical decision-making.
• Collaborate in ongoing co-management with technology-supported care to improve patient outcomes.

IV. Payers and their delegated technology

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.

Additional Use Case (Optional): Electronic Prior Authorization

Payers may:

• Implement FHIR-based prior authorization APIs conformant with HL7 FHIR Da Vinci standards
• Support consistent medical prior authorization workflows
• Provide timely status updates, decision outcomes, and standardized denial reason codes
• Enable auditability of prior authorization events across the lifecycle
• This pledge is in support of the Landmark ePA pledge of Summer 2025 for Payers

Additional Use Case (Optional): Real-Time Benefits

Payers may:

• Deliver accurate, real-time, patient-specific cost and coverage information across both prescription and medical benefits through standardized APIs, including the Consumer Real-Time Pharmacy Benefit Check (RTPBC) FHIR IG and the entire CARIN Digital Insurance Card FHIR IG, including the Summary of Benefits Coverage insurance profile.
• Expose digital insurance coverage and structured plan design via FHIR APIs, reducing reliance on portals, call centers, and manual workflows.

Additional Use Case (Optional): Bulk FHIR

Payers may:

• Support asynchronous Bulk FHIR export workflows for payer, provider, research, and CMS-aligned use cases.
• Demonstrate operationally usable performance at realistic scale and participate in transparent performance measurement.

V. 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:
   1. 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.
   2. 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).
   3. Participate in CMS review, including disclosure of data sources, terms/agreements and a basic security checklist.
   4. Offer trial access for Medicare patients if the app charges a fee.
   5. 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).
   6. 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
   2. 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).
   3. 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.
   4. 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.

• Optionally, meet any of the following additional use cases
  • Modern Scheduling
    • Enable patients to discover, book, reschedule, and cancel appointments in real time without portal or phone dependency.
  • Price Transparency
    • Deliver patient-specific estimates of expected out-of-pocket costs that reflect each patient's individual health plan benefits, cost-sharing responsibilities, and current plan status, before services are delivered.
  • Real-Time Benefits
    • Present accurate, real-time, patient-specific cost and coverage information across prescription and medical benefits.
  • Clinical Trial Matching
    • Integrate the ClinicalTrials.gov API and computable protocol standards so patients can discover relevant clinical trials within app experiences.

VI. Additional Use Case: Electronic Prior Authorization

Objective:

Enable a real-time, API-driven prior authorization ecosystem that integrates seamlessly into clinical workflows, allowing providers to submit and track requests and patients to access faster, more transparent care. This effort reduces manual processes and establishes interoperable, end-to-end workflows across the healthcare system.

Payers must:

• Implement FHIR-based prior authorization APIs conformant with HL7 FHIR Da Vinci standards
• Support consistent medical prior authorization workflows
• Provide timely status updates, decision outcomes, and standardized denial reason codes
• Enable auditability of prior authorization events across the lifecycle

Providers must:

• Submit and manage prior authorization requests electronically within clinical workflows
• Reduce reliance on fax, portals, and other manual processes

EHRs must:

• Implement FHIR-based prior authorization capabilities conformant with HL7 FHIR Da Vinci standards
• Enable real-time submission, documentation exchange, and status tracking
• Support ordering workflows associated with medical prior authorization

VII. Additional Use Case: Price Transparency

Objective:

Give patients access to timely, personalized cost information before services are delivered, supporting informed conversations with providers and better healthcare decision-making.

Pledgees must:

• Implement CMS Interoperability Framework criteria and work collaboratively to accelerate implementation of Good Faith Estimates using standardized formats.
• Leverage existing data sources, including claims infrastructure, Transparency in Coverage (TiC) data, hospital price transparency data, and X12 and HL7 FHIR standards.
• Deliver patient-specific estimates of expected out-of-pocket costs through patient-facing applications (PFAs) by combining these data sources with provider and payer information.
• Ensure estimates reflect each patient's individual health plan benefits, cost-sharing responsibilities, and current plan status, providing more meaningful and accurate information before services are delivered.

VIII. Additional Use Case: Real-Time Benefits

Objective:

Deliver accurate, real-time, patient-specific cost and coverage information across both prescription and medical benefits, helping providers get paid what they are owed and giving consumers lower out-of-pocket costs and more transparency on their benefits.

Pledgees must:

• Deliver patient-specific cost and coverage information in real time across both prescription and medical benefits through standardized, interoperable APIs, including the Consumer Real-Time Pharmacy Benefit Check (RTPBC) FHIR IG and the entire CARIN Digital Insurance Card FHIR IG, including the Summary of Benefits Coverage insurance profile.
• Expose digital insurance coverage and structured plan design via FHIR APIs, helping to ensure responses are patient-specific, accurate, and real-time.
• Reduce reliance on portals, call centers, and manual workflows for benefit and coverage information.

IX. Additional Use Case: Modern Scheduling

Objective:

Make scheduling capability so patients can discover, book, and manage appointments through apps without portal or phone dependency, enabling seamless scheduling across the ecosystem.

Pledgees must:

• Make appointment discovery, booking, and management available in real time through open, standardized FHIR APIs using the Schedule, Slot, and Appointment resources.
• Expose accurate, current scheduling data, whether powered directly by source systems or by cloud-based FHIR data stores.
• Support real-time booking, rescheduling, and cancellation so patients can access scheduling through apps without portal or phone dependency.

X. Additional Use Case: Clinical Trial Matching

Objective:

Close the clinical trial awareness and matching gap so trial discovery no longer depends on individual clinician awareness alone, consistent with HHS's Operation TrialBlazer, helping to ensure every eligible patient has the opportunity to learn about and consider relevant clinical trials.

Pledgees must establish two complementary pathways:

• A compliant, claims-informed channel that routes population-level trial eligibility signals, including those identified within the CMS Virtual Research Data Center (VRDC), to treating providers, never directly to patients.
• App- and EHR-based matching that integrates the ClinicalTrials.gov API and computable protocol standards (CDISC USDM, HL7 FHIR, ICH M11 ceSHarP) so patients and providers can discover relevant trials directly within care and app experiences.

XI. Additional Use Case: Bulk FHIR

Objective:

Advance scalable, standards-based population data exchange using HL7 FHIR Bulk Export. Interoperable healthcare depends not only on standards compliance, but on reliable, predictable, and scalable exchange that supports quality measurement, care management, research, public health, and AI innovation.

Pledgees must:

• Support asynchronous Bulk FHIR workflows for payer, provider, research, and CMS-aligned use cases.
• Demonstrate operationally usable performance at realistic scale, including exports involving hundreds of thousands to millions of records, to the extent permitted by law.
• Participate in transparent performance measurement.
• Collaborate to improve real-world implementation of Bulk FHIR exchange.

XII. Diagnostic Imaging Acceleration ("Ditch the Disk") Workgroup

Objective:

Make imaging data retrievable across organizations, within clinical workflows, and by patients completely, quickly, and without friction, eliminating physical media where digital exchange is possible.

Official Pledge Coming Soon!

Early adaptor within the workgroup: 

XIII. 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.

XIV. 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.

XV. State

Objective:

Enable states to play an active, coordinating role in ensuring full participation across providers, payers, and patient-facing tools, helping build a comprehensive, interoperable health information ecosystem statewide.

States will:

• Support Provider & Network Participation: Encourage providers and health systems to join at least one CMS Aligned Network so patient data is shareable across the care continuum.
• Ensure Payer Connectivity: Require state-administered payers (e.g., Medicaid, state-regulated plans) to connect to a CMS Aligned Network and make claims (and, where appropriate, clinical) data available for exchange under the CMS Interoperability Framework.
• Foster Patient-Facing Innovation: Promote and support patient-facing applications (e.g., mobile health apps, personal health record tools) that connect via CMS Aligned Networks, ensuring patients statewide benefit from modern, convenient access to their health data.
• Coordinate Across Stakeholders: Act as a convening body to align state regulators, providers, payers, and technology partners around interoperability, facilitating outreach, onboarding, and alignment with federal (CMS) criteria.
• Measure & Report Progress: Monitor state-level participation and connectivity (providers, payers, apps), assess gaps, and report status publicly (or to CMS) to drive accountability and improvement.