June 16, 2025
PALTmed has written a response to the Centers for Medicare & Medicaid Services (CMS) Request for Information on the Health Technology Ecosystem, advocating for inclusion of post-acute and long-term care (PALTC) clinical and facility providers in federal health IT modernization efforts. PALTmed emphasized that current digital health policies often overlook the unique challenges PALTC settings face.
PALTmed’s comments call on CMS and the Assistant Secretary for Technology Policy/Office of the National Coordinator for Health Information Technology (ASTP/ONC) to take targeted steps to ensure PALTC settings are fully integrated into the national health information exchange landscape. Key recommendations include:
- Funding and Infrastructure: Provide financial incentives for PALTC to adopt certified, interoperable EHR systems and expand broadband access in rural areas, where digital infrastructure is often lacking.
- PALTC-Specific Solutions: Develop EHR functionalities tailored to the care coordination, medication reconciliation, and transitional needs of PALTC clinicians.
- Streamlined Reporting: Support automated, real-time quality reporting through Bulk FHIR and reduce duplicative documentation that burdens already stretched staff.
- Inclusion in Standards Development: Ensure PALTC stakeholders are involved in developing interoperability standards, and that their workflows and needs are reflected in data exchange policies like TEFCA and FHIR API frameworks.
PALTmed warned against punitive interoperability mandates, such as payment penalties or checkbox reporting, arguing that such measures would strip critical resources from underfunded facilities. Instead, the association urged CMS to focus on supportive policies that make digital health tools practical and accessible in all care settings.
Highlighting the fragmentation of current systems, where hospitals often fail to share data with SNFs and vice versa, PALTmed reinforced the urgency of building a truly connected care continuum and stressed the value of nationwide FHIR endpoint directories and the expansion of the US Core Data for Interoperability (USCDI) to better represent the needs of PALTC clinicians and patients. Today, PALTC clinicians are overburdened by a system that does not work. Often, clinicians must deal with a multitude of EHRs that do not speak to one another. This leads to burdens and takes time away from clinical care. Worse than that, it brings patients harm. Medication errors due to incomplete medical lists or lack of clear information on the latest diagnosis and medication list are common failures of today’s transitions of care. This must be resolved by sharing meaningful data in a user-friendly format.
Ultimately, PALTmed’s message to CMS is clear: To achieve equity, efficiency, and better outcomes in health care, PALTC must be treated as an integral part of the digital health ecosystem, not an afterthought. Ensuring PALTC providers are equipped with the tools, infrastructure, and policy support needed to deliver high-quality, coordinated care remains central to PALTmed’s mission and ongoing federal engagement efforts.
