Elation Health Champions Primary Care in Response to CMS and ASTP/ONC Health Technology Ecosystem RFI
Elation Health recently submitted a response to the CMS and ASTP/ONC Health Technology Ecosystem Request for Information (RFI), reaffirming our leadership in policy advocacy and our unwavering commitment to empowering primary care. For those unfamiliar with this RFI, it sought input from the public regarding the market of digital health products for Medicare beneficiaries as well as the state of data interoperability and broader health technology infrastructure. Resulting responses could be used to lead future infrastructure policy and investments to specifically help stakeholders make informed health decisions and increase data availability for everyone contributing to health outcomes.
As one of the 980 responders to the RFI, Elation brings a unique, frontline perspective to national digital health policy—offering critical insights on reform that truly serve patients, physicians, and communities. Our message to policymakers was straightforward: the core obstacle to better technology and interoperability isn’t technical—it’s the lack of alignment between incentives and the real needs of primary care. To unlock a health system that rewards longitudinal, whole-person care, Elation called for bold changes to structural issues in U.S. policy, with particular focus on the most powerful lever CMS has: primary care payment.
Future Health Tech Success Must Center Primary Care
Elation’s submission highlights a shared vision for a less burdensome and more patient-centric digital health ecosystem. The emphasis is on the need to reduce the administrative and financial burdens that weigh down primary care practices.
Elation’s recommendations, which were aligned with comments from industry leaders also engaged in the all-important work of primary care advocacy, such as the American Academy of Family Physicians (AAFP), the American College of Physicians (ACP), and the Medical Group Management Association (MGMA), focused on five key areas:
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Reform Market Incentives: Elation believes that payment reform is the most powerful tool for driving market demand for patient-centered technology. By increasing prospective, value-based payments to primary care, CMS can create a market that rewards longitudinal, whole-person care and incentivizes both the development and the adoption of better tech.
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Prioritize Primary Care: The Elation response called for policymakers to recognize primary care as both the central use case for interoperability and its primary beneficiary, ensuring that policies are designed with coordinated, longitudinal, whole-person care in mind. This sentiment was echoed by organizations like the AAFP, which consistently positions primary care as foundational to a high-value healthcare system.
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Overhaul Certification Requirements: The current certification model relies on technical checklists mandating low-value features that would naturally be market-corrected. Elation argues for a shift toward real-world, outcome-focused, high-value use cases.
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Reduce Administrative Burden: Elation is urging CMS to centralize and standardize quality reporting, performing quality calculations itself using bulk FHIR data and ending the need for redundant third-party reporting and fragmented quality measurement, to free clinicians and allow them to focus on their patients.
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Modernize Data Standards: Our submission advocates for a pragmatic approach to modernizing data standards. FHIR should be a minimum baseline and proprietary APIs retain value for complex cases, but AI is rapidly making the choice of standard less important by enabling translation and structure of unstructured health data. By embracing advances in AI, we can support regulatory flexibility that fosters innovation.
Elation’s CEO Lifts up the Voices of Primary Care Physicians
To further elevate primary care’s voice in future policy, Elation CEO Kyna Fong shared her perspectives live at the CMS and ASTP/ONC Health Technology Ecosystem RFI listening session in Washington, D.C. on the "Unleashing the Digital Health Ecosystem" panel in early June 2025. The event brought together a diverse group of stakeholders—including patients, caregivers, technology companies, data providers, healthcare organizations, and payers—to share insights and best practices for leveraging digital health technologies to reduce fraud, minimize administrative burdens, and improve care quality for millions of beneficiaries.
During her panel session, Kyna underscored the need to put primary care front and center in health technology reform. She emphasized that genuine progress starts with aligning financial incentives to reward whole-person care—empowering primary care to drive market demand for the tools they truly need. Rather than getting lost in technical checklists, she called for a shift to outcome-based standards and frictionless data exchange, urging regulators to focus policy on real-world impact for both clinicians and patients as artificial intelligence continues to unlock new possibilities for interoperability.
CMS used this event to reaffirm its commitment to several key initiatives aimed at building the foundational infrastructure for a modernized healthcare ecosystem. It’s inspiring to see CMS and the ASTP/ONC engaging with the industry to drive positive progress on crucial issues like data standards, digital health infrastructure, and interoperability.
Primary Care Advocacy is a Non-Negotiable
For primary care to succeed, policy advocacy must sit alongside technology innovation. Elation is proud to be a steadfast advocate for policies that put primary care first—from payment transformation and EHR certification to reducing bureaucracy and delivering meaningful interoperability. We champion reforms that free clinicians to focus on the craft of medicine, foster high-value care, and drive better outcomes for everyone.
Policy decisions shape the future of care. That’s why Elation will continue to elevate primary care voices, advocate for practical reforms, and build trusted technology—enabling physicians to do what they do best: care for their communities.