NCQA Responds to the HHS Health Technology Ecosystem RFI

June 30, 2025 · Eric Musser, MPH

Eric Musser, Vice President, Federal Affairs, NCQA

NCQA submitted a comprehensive response to the Department of Health and Human Services (HHS) Request for Information (RFI) on the Health Technology Ecosystem. Our response outlines strategic recommendations and concrete steps NCQA is taking to support a modern, interoperable and trusted digital health infrastructure.

Purpose of the Health Technology Ecosystem RFI

The Centers for Medicare & Medicaid Services (CMS) and the Assistant Secretary for Technology Policy/Office of the National Coordinator for Health Information Technology (ASTP/ONC) are working together to strengthen the digital health ecosystem. Their goal is to promote widespread adoption of health management and care navigation tools, improve data access and exchange, and support innovations that lead to better health outcomes.

To shape future policies, CMS and ASTP/ONC are gathering feedback from a wide range of stakeholders on what’s working in digital health, what needs improvement and what barriers still exist. There are five categories of RFI questions: patients, providers, payers, technology vendors and value-based care organizations. NCQA provided comments and recommendations on applicable questions in each category.

Key Themes and Recommendations

The cross-cutting theme of NCQA’s recommendations is that CMS and ASTP/ONC should accelerate the transition to digital quality measurement to support a more interoperable and trusted digital health infrastructure. We also present solutions we are developing to address the challenges described in the RFI.

1. Empowering Patients and Caregivers

As digital tools become more central to how patients manage their health—particularly outside traditional clinical encounters—patients, caregivers and providers will need to be able to identify the tools that improve health outcomes and drive down health care costs.

NCQA’s Recommendations

• Promote third-party evaluation of digital health tools to build trust and usability.
• Develop a CMS-endorsed directory of certified tools, and incentivize integration into EHRs to support care coordination.
• Integrate disparate data sources, including pharmacy, behavioral health, social determinants and patient-generated health data (e.g., wearables), to create a more complete, person-centered view of health.

How NCQA Can Help

NCQA is developing a program that defines and evaluates high-quality digital condition management, and we plan to launch a pilot with up to 10 health care organizations this fall.

2. Supporting Providers

A significant obstacle to innovation in clinical workflows for quality measurement is reliance on outdated data standards such as the Quality Data Model (QDM) and Quality Reporting Document Architecture (QRDA). These standards were developed for electronic clinical measures, but aren’t widely used outside quality reporting, which limits interoperability and increases implementation burden.

NCQA’s Recommendations

• Retire outdated standards like QDM and QRDA and incentivize the use of HL7^® FHIR^® and CQL for quality measurement.
• Invest in tooling, technical assistance and community support to help providers and vendors adopt FHIR-based reporting and CQL-based logic.
• Align quality reporting with clinical workflows to reduce duplication and administrative burden.

How NCQA Can Help

NCQA is developing an Advanced Primary Care program that integrates digital quality measurement, care coordination and interoperability into a single, scalable solution. It draws on our experience with the PCMH Recognition program and digital HEDIS^®, ensuring compatibility with modern health IT infrastructure and enabling real-time, patient-centered performance measurement.

3. Enabling Payers

Payers need access to electronic clinical data to reduce manual reporting and promote interoperability. While TEFCA provides a framework for accessing these data, lack of clarity about data exchange fees and uncertainty about data quality creates hesitation.

NCQA’s Recommendations

• Clarify data exchange fee policies under TEFCA, and integrate data quality validation into its framework.
• Expand TEFCA’s technical capabilities to include Bulk FHIR and other scalable mechanisms for quality measurement and reporting.
• Introduce Medicare Advantage Star Ratings metrics that reward standardized, bidirectional data exchange.
• Establish an early adopters program for organizations that implement APIs ahead of regulatory timelines.

How NCQA Can Help

NCQA’s Electronic Clinical Data Systems (ECDS) reporting method for HEDIS enables the use of structured electronic clinical data from EHRs, registries and other digital sources, eliminating the need for manual chart abstraction. ECDS measures are already in use across CMS programs: the Medicaid Adult and Child Core Sets, the Marketplace Quality Rating System and the Medicare Advantage Star Ratings program. NCQA recently announced plans to transition additional HEDIS measures to ECDS reporting in the coming years.

4. Engaging Technology Vendors and Networks

Technology vendors and networks operate on the front lines of the digital transformation. To spur innovation, they need a modern, standards-based infrastructure that developers can build on—one that supports real-time data exchange, scalable quality measurement and seamless integration into clinical workflows.

NCQA’s Recommendations

• Encourage implementation of FHIR APIs and Bulk FHIR to enable real-time, scalable data exchange.
• Invest in shared infrastructure and services that developers can leverage to build scalable, standards-aligned solutions.
• Prioritize API performance, usability and real-world impact in technology certifications.
• Support a dual participation model that allows organizations to engage in both TEFCA and state/regional networks.

How NCQA Can Help

NCQA’s Digital Content Services provides a centralized, certified source of digital quality measure logic that vendors can integrate directly into their workflows, products and solutions—such as EHRs, analytics platforms and care coordination tools. Our Bulk FHIR Quality Coalition assesses the real-world feasibility of data exchange between payers and providers using HL7 FHIR APIs.

5. Advancing Value-Based Care

To successfully participate in value-based care arrangements, health care organizations must have access to timely, accurate and standardized data for evaluating performance and improving outcomes.

NCQA’s Recommendations

• Systems must support interoperable data exchange using HL7 FHIR standards and CQL for automated quality measurement.
• Value-based care models should use validated data for fair and effective performance evaluation.

How NCQA Can Help

NCQA’s HEDIS audit process helps ensure that data used to calculate performance measures are complete and accurate, and conform to rigorous specifications. Audited HEDIS data are already used in CMS Medicare Star Ratings, Medicaid managed care and commercial value-based contracts. HEDIS measures are trusted by regulators and payers, and provide a consistent benchmark for comparing performance across plans and populations.

Learn More

• Read NCQA’s full comment letter here.
• Download NCQA’s Recommendations for the Trump Administration here.

HEDIS is a registered trademark of the National Committee for Quality Assurance (NCQA).

HL7^® and FHIR^® are the registered trademarks of Health Level Seven International and their use does not constitute endorsement by HL7.