Epic's CMS Response: Unlocking Health Tech Opportunities for Entrepreneurs

Table of Contents

Abstract

I. Introduction: The Shifting Healthcare Technology Landscape

II. The National Healthcare Directory: Infrastructure as Opportunity

III. Digital Identity Revolution: Building the Patient-Centric Future

IV. TEFCA's Expansion: The New Highway for Health Data

V. Certification Streamlining: Lowering Barriers to Innovation

VI. Quality Measurement Evolution: Data-Driven Healthcare

VII. Information Blocking Clarity: Creating Safe Harbors for Innovation

VIII. Strategic Implications for Health Tech Entrepreneurs

IX. Conclusion: Seizing the Moment

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Abstract

Epic's comprehensive response to the Centers for Medicare and Medicaid Services (CMS) Request for Information on the Health Technology Ecosystem reveals unprecedented opportunities for health tech entrepreneurs and vendors. This analysis examines seven key areas where Epic's recommendations could fundamentally reshape the healthcare technology landscape:

• National Healthcare Directory: Creation of a unified, federated directory system requiring specialized implementation services and integration solutions

• Digital Identity Infrastructure: Development of interoperable credential service providers and patient-centric identity management tools

• TEFCA Expansion: Broadening use cases for the Trusted Exchange Framework creating new API-based business models

• Certification Streamlining: Reducing regulatory barriers while maintaining interoperability standards

• Quality Measurement Evolution: Transition to FHIR-based reporting systems and real-time analytics

• Information Blocking Safe Harbors: Clear compliance pathways encouraging innovation and market entry

• LLM Integration: Opportunities for AI-powered healthcare applications using structured and unstructured data

These recommendations signal a shift toward open, standardized, and patient-controlled healthcare data ecosystems, creating fertile ground for entrepreneurial innovation across infrastructure, applications, and services.

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I. Introduction: The Shifting Healthcare Technology Landscape

The healthcare technology ecosystem stands at an inflection point, with Epic's detailed response to the CMS Health Technology Ecosystem Request for Information serving as both a roadmap for systemic change and a treasure map for entrepreneurial opportunity. As one of the most influential electronic health record vendors in the United States, Epic's recommendations carry significant weight in shaping federal policy and industry standards. More importantly for health tech entrepreneurs, these recommendations reveal gaps in the current infrastructure and articulate a vision for a more open, interoperable healthcare ecosystem that will require extensive innovation to implement.

Epic's response, submitted in June 2025, represents more than mere regulatory commentary. It functions as a blueprint for the next generation of healthcare technology infrastructure, one that prioritizes patient access, reduces administrative friction, and creates standardized pathways for data exchange. The document spans eighteen pages of detailed technical recommendations covering everything from national healthcare directories to digital identity frameworks, each section revealing specific opportunities where innovative startups and established vendors can create value.

The timing of this response coincides with broader trends in healthcare technology, including the maturation of Fast Healthcare Interoperability Resources standards, the growing adoption of application programming interfaces for health data access, and increasing regulatory pressure for patient data portability. These convergent forces create a unique moment where technical possibility, regulatory mandate, and market demand align to create unprecedented opportunities for entrepreneurs who can navigate the complex intersection of healthcare, technology, and regulation.

Understanding Epic's recommendations requires appreciating the company's unique position in the healthcare ecosystem. With implementations across more than 1,150 hospitals and 25,500 clinics, Epic's software manages health records for hundreds of millions of patients. When Epic advocates for specific technical approaches or regulatory frameworks, it signals not just policy preference but practical roadmaps for implementation at massive scale. For entrepreneurs, this represents both opportunity and guidance, as Epic's recommendations often become de facto industry standards.

The response also reveals Epic's strategic shift toward more open, standards-based approaches to healthcare data exchange. This evolution from a historically proprietary approach toward embracing open APIs, FHIR standards, and federated data architectures creates substantial opportunities for complementary technologies and services. Entrepreneurs who can build solutions that integrate seamlessly with Epic's ecosystem while addressing gaps in functionality or serving underserved market segments will find receptive customers and clear technical pathways for integration.

II. The National Healthcare Directory: Infrastructure as Opportunity