CMS Health Tech Ecosystem RFI: National Directory Comments

In its recent Request for Information (RFI) on the Health Tech Ecosystem, CMS posed questions about the value and feasibility of a Nationwide Provider Directory. These questions included:

What impact would mandatory credentials have on a nationwide provider directory?
What would be the value to payers of a nationwide provider directory that included FHIR endpoints and used digital identity credentials?
How could a nationwide provider directory of FHIR endpoints improve access to health information for patients, providers, and payers? Who should publish such a directory, and should users bear a cost?
How could a nationwide provider directory of FHIR endpoints help improve access to patient data and understanding of claims data sources? What key data elements would be necessary in a nationwide FHIR endpoints directory to maximize its effectiveness?

CMS received over 1,367 comments from payers, providers, technology vendors, academic centers, associations, and other industry stakeholders. With the help of Josh Mandel’s CMS RFI Comment Analysis Dashboard and a structured review of individual comments, we organized industry feedback into recurring themes. Below is a synthesis of industry perspectives, with selected quotes from named respondents.

1. A national directory could reduce administrative burden

Theme: Many respondents agreed that a well-structured national directory would reduce redundant work and relieve providers and payers of duplicative data entry, collection, and validation.

American College of Physicians: “A nationwide physician directory would help reduce administrative costs, enabling payers to exchange claims and prior authorization data more efficiently.”
BCBS Association: “A nationwide provider directory that integrates FHIR endpoints and digital identity credentials would significantly improve the accuracy and efficiency of managing provider data for payers, providers, and patients. It will alleviate the burden on providers and payers of updating numerous directories and verifying information in multiple locations frequently.”
Colorado Access: “If a nationwide provider directory contains detailed, reliable, and up-to-date provider information that eliminates the need for payers to curate this information independently, significant administrative savings could be realized and reinvested into the maintenance of the nationwide directory.”
Fairview Health Services: “There is an opportunity to reduce the administrative burden associated with maintaining multiple contracts with third-party vendors and eliminate duplicative efforts across states and organizations… The current system of collecting provider data is fragmented, requiring Minnesota payers to obtain provider data from multiple sources (delegate provider files, the Minnesota Credentialing Collaborative, and proprietary provider application systems). A nationwide provider directory would allow providers to update information in a single place, improving data quality and reducing administrative burden on providers.”
Kaiser Permanente: “Kaiser Permanente supports CMS seeking ways to improve provider directory accuracy and functionality, while reducing associated administrative burden.”
Oscar: “We envision many benefits from a national provider directory, including allowing for more accurate provider information; alleviating administrative burden for providers, payers, and other third-parties; and providing current data to inform network adequacy and accuracy.”
Zelis: “Additionally, the larger healthcare system, as well as taxpayers, would benefit greatly from the reduced administrative waste stemming from CMS publishing and maintaining a nationwide provider directory, which would more than offset the cost of owning and operating that directory.”

2. A national directory could promote interoperability

Theme: A directory of FHIR endpoints would promote interoperability and could lead to broader adoption and use of APIs among payers, providers, and patients to exchange data with one another.

Ascension: “Moreover, establishing a nationwide provider directory of FHIR endpoints—including provider IDs, endpoint URLs, and FHIR versions—and integrating it with TEFCA would significantly improve data accessibility and clarity across care settings.”
BCBS Association: “A nationwide provider directory of FHIR endpoints would be transformative in advancing interoperability by providing a centralized, standardized repository of API endpoints for providers, payers, and other healthcare entities.”
BCBS Massachusetts: “A nationwide provider directory that included FHIR end points and used digital identity credentials is a meaningful goal that would help to facilitate interoperability on a national scale and enable use cases that will support payment and operational activities, in addition to treatment activities.”
ChenMed: “A nationwide provider directory of FHIR endpoints would be a powerful tool for improving interoperability, care coordination, and administrative efficiency—especially for multi-state organizations and patients who receive care across different health systems.”
Cleveland Clinic: “A nationwide provider directory of FHIR endpoints would facilitate seamless data exchange across various healthcare providers, without the need for the cumbersome process of downloading, transferring, and uploading files, thus improving continuity of care.”
Datavant: “A nationwide provider directory of FHIR endpoints could significantly improve access to health information for patients, providers, and payers by:
- Facilitating seamless data exchange: It would simplify the process of locating and connecting to provider data endpoints, accelerating data fl ow and improving care coordination.
- Enhancing interoperability: It would provide a centralized resource for discovering FHIR-based data access points, promoting broader interoperability across the healthcare ecosystem.”
Kyruus: “Furthermore, we urge CMS to actively avoid information blocking scenarios (TD-5; PC-2c) and to incentivize the widespread adoption and exposure of open, standards-based APIs like FHIR, potentially by requiring vendors to disclose their API usage and standards in CMS programs (TD-4).”
Leavitt Partners: “The lack of a national health care directory that accurately represents relationships of individual licensed practitioners to different practice groups and health systems, making it hard for consumers to locate the right API endpoints.”
Lumeris: “A nationwide provider directory of FHIR endpoints would significantly improve access to patient data and enhance understanding of claims data sources by serving as a central, authoritative resource for discovering where and how to connect with different healthcare organizations’ digital systems.”
Microsoft: “A free, publicly available, and machine-readable national directory of healthcare provider/system electronic service endpoints and capabilities is needed. This simplifies connections and reduces friction for developers, providers, patients, and payers.”
Oscar: “FHIR endpoints would allow for easier integration with other FHIR-based APIs required by CMS and maintained by certain payers, thereby improving interoperability.”
Redox: “Accelerate sharing of data via FHIR over a trusted exchange and help accelerate the necessary components to ensure that this can scale, such as FAST security IG and make the location of the data searchable and discoverable via a Nationwide endpoint directory.”
UnitedHealth Group: “Create a national endpoint directory and record location services to facilitate the programmatic, accurate exchange of information between payers, providers, and other participants consistent with privacy and security standards. It should be easy for anyone to discover and retrieve the data for any individual regardless of where the data resides. This must be possible without having to explicitly know which systems have data for a patient”

3. A national directory could help patients pick plans and providers

Theme: A national directory could broaden the availability of information about health plans and providers, allowing patients to discover the best plans and providers for them.

Association of American Medical Colleges: “Health plan directories are often the first source used by patients to identify healthcare providers and check whether a clinician is within their health plan’s network and taking on new patients. But too often, health plan directories contain outdated or even erroneous information, frustrating, or even harming patients. The AAMC strongly supports efforts to build stakeholder consensus to inform the future development of a centralized solution to improving health plan directories to improve patient experience and reduce burden for providers.”
American Dental Association: “Patients often struggle to find providers who not only accept their insurance benefits but also accept new patients. Dental payer-based provider directory APIs frequently contain outdated or incomplete data, resulting in ‘ghost’ networks.”
American Hospital Association: “In particular, we are supportive of the Provider Directory API that allows patients to discover in-network providers with the most accurate and up-to-date lists.
American Osteopathic Association: “When searching for an MA plan on the Medicare Plan Finder (MPF), beneficiaries can narrow down options using filters for plan benefits, insurance carriers, drug coverage, and star ratings. However, if the beneficiary would like to choose a plan that allows them to continue to see their current physician, the beneficiary must go to the plan’s website and review the provider directory. If a patient sees multiple physicians and is considering several plans, the process of selecting a plan can be tedious and confusing when information is not in a single place.”
Availity: “We believe a central store of provider data, accessible through FHIR endpoints, can establish a single source of shared truth for American consumers. This data would drive access to care by matching a patient’s health needs to capable and available providers, all while driving out harmful ghost networks.”
Claritev: “Areas of opportunity include access to accurate and timely data about providers, such as updated addresses, hours of operations, status of associated providers and services, quality scores, patient experience, scheduling tools and fee schedules. These attributes are important for patients and their caregivers to make informed decisions about available care pathways and for payors to quickly adjudicate and pay claims.”
ChenMed: “Supporting patient access and choice: Patients could more easily find providers and access their health information through a standardized directory, empowering them to make informed decisions and fostering competition among providers.”
CVS Health: “Every patient and consumer should be able to easily find a clinician or facility skilled in the type of care they seek. We urge CMS to work in partnership with the private sector to establish a national directory of plans and providers that solves not only the need for endpoints but also demographic data.”
Google: On the topic of a beneficiary navigator: “Facilitate Care Navigation: After answering a question, the assistant could say, ‘Dr. Smith is a high-quality, in-network provider in your accountable care organization with availability next Tuesday. Would you like me to help you schedule an appointment?’ This integrates provider directories, quality data, and scheduling into a single, seamless workflow.”
ZocDoc: “CMS should completely transform the Medicare Compare tool by integrating a bookable directory directly into the site. This is a common sense, cost-saving, fraud-detecting solution that could be deployed quickly and would deliver real results for the American people, leveraging proven technology to improve healthcare.”

4. CMS should ensure that provider burden is actually reduced

Theme: Providers cautioned that CMS should avoid creating “yet another portal” and emphasized the importance of delegation (of data entry) and automation to reduce maintenance burden.

American Academy of Family Physicians: “The AAFP believes having a single place to maintain a digital identity and accompanying physician-specific data would be very helpful to family physicians, and we appreciate CMS and ASTP/ONC’s thoughtful consideration of how these topics potentially interact. The AAFP encourages the agencies to not mandate anything before a properly developed system featuring user-centered design has been established; to do otherwise would most likely result in an increase in administrative burden.”
American Hospital Association: “Moreover, the AHA urges ONC/ASTP and CMS to ensure that the Provider Directory API replaces other existing provider information data sets. Steps must be taken to ensure that the Provider Directory API does not simply become an additional data source available to patients without sufficiently addressing how or why it differs from the myriad provider directories already in existence, and to ensure that it does not complicate patients’ abilities to access accurate information. Further, work on provider directories must reduce — not contribute to — provider reporting burden and ensure adequate testing and standardization of health information and data transmission.”
American Medical Association: “It is imperative, however, that any new directory does not create yet another place for physicians and practices to submit and update data adding to already significant administrative burden and taking time away from patient care.”
BCBS Association: “Typically, individual providers do not possess an endpoint; instead, the endpoint will be associated with an organization. Therefore, understanding provider affiliations is crucial.”
Colorado Access: “CMS should prioritize gaining provider consensus on directory update best practices, and explore technical development of a nationwide provider directory only after securing buy-in from providers of varying specialties and sizes across geographic locations.”
Doximity: “We believe physicians deserve a modern, automated solution that reflects the realities of how they practice and interact with today’s digital systems. Too often, clinicians spend valuable time updating profile information across numerous disconnected directories, a process that creates duplication, inconsistency, and ultimately frustration… Unfortunately, these sites can be poorly designed, leaving physicians uncertain about which details will remain private and which will be publicly accessible.”
Texas Medical Association: “Maintenance responsibilities must not fall to individual physicians or practices, and any usage fees should be federally subsidized. An easy-to-use clinician portal to allow individuals to securely update their demographics should be provided.”

5. Some advocate for a federated architecture

Theme: Several commenters proposed a federated model that pulls from existing trusted sources rather than creating an entirely new system from scratch. Data imports from pre-existing systems could accelerate the availability of data within a national directory, but it also persists the existence of multiple, disparate portals. This could be solved with robust data governance rules and API-based data exchange.

American Dental Association: “Systems that maintain provider data for purposes such as credentialing can easily be adapted to support use cases such as directories without the need for duplicative systems. Despite these efforts, there continues to be a proliferation of directory solutions, often required by mandate for participation in state Medicaid programs. The need to maintain accurate information in a provider directory is placed onto the dental practice. Failure to implement a single source of information leads to significant duplication of effort by providers and practices and creates data inconsistencies.”
CAQH: “Welcomes the opportunity to work in collaboration with CMS to build on existing infrastructure, minimizing disruption, avoiding duplication, and accelerating progress toward shared goals.”
CVS Health: “To aid with alleviating provider friction points and improve the accuracy of provider credentialing and timely provide communications, CMS should develop the nationwide directory using a federated model supported by a public-private partnership rather than centralized control by CMS.”
Epic: “The directory should be a unified database populated by the unambiguous source of truth for each data element needed by the ecosystem. CMS should own provider identity, including name and National Provider Identifier (NPI), since the National Plan and Provider Enumeration System (NPPES) is the primary source for provider identity information. Other organizations should be the source of truth for their relationship with the provider. This hybrid model—centralized identity, federated context—is the only approach that acknowledges the realities of today’s healthcare operations and positions the national directory as a trusted, scalable foundation for interoperability. Without it, the government risks recreating the same disjointed, error-prone directory infrastructure that it aims to replace.”
H1: “CMS should focus on policy to encourage industry-standard APIs and data sharing, while relying on established solutions for implementation. Rather than rebuilding provider directories, CMS can make use of best-of-breed private data feeds. For example, CMS may recognize certified private directories as acceptable data sources in regulatory requirements (e.g. Conditions of Participation or pay-for-performance measures). This prevents duplication: the RFI and prior rulemakings note that private providers have already developed sophisticated directory exchanges (VB-5).”
Kaiser Permanente: “We recommend that a national provider directory function as a federated infrastructure that can aggregate and index authoritative data sources without replacing or duplicating public facing health plan provider directories. As provider directories can offer consumer-facing engagement and brand assets, stakeholders should retain operational control over their respective data (e.g., payers over network relationships, providers over practice locations).”
Medical Group Management Association (MGMA): “MGMA supports the development of a nationwide provider directory that builds on existing tools and interoperability strategies to facilitate patients’ access to care. It is imperative that efforts to create a provider directory leverage existing private sector directories (such as the CAQH credentialing database). Creating entirely new systems and processes for provider directories is unnecessary given existing initiatives and would only force medical groups to submit duplicative information. Moving towards a national directory also provides the opportunity for CMS to work with other stakeholders such as health plans to improve their workflows.”
UnitedHealth Group: “Partner with CMS, the Council for Affordable Quality Healthcare (CAQH) and other public and private sector partners to develop a single authoritative provider directory accessible via APIs to reduce provider and payer burden, help consumers, and lower administrative costs.”

6. Forget data entry: get the data from EHRs and other systems

Theme: Some respondents emphasized that providers often do not know their own FHIR endpoints, and that endpoint data should instead be provided by EHR vendors. Similarly, information about provider demographics and appointment availability exists within EHRs and could be sourced directly from EHRs.

American Medical Association: “Following these processes can lead to additional standards-based system-to-system integration that allows bulk and real-time updates and opportunities to harmonize data systems and eliminate data siloes.”
Better Medicare Alliance: “Such an approach is necessary to streamline collection of information, improve accuracy, and to allow connections with other data management systems/Electronic Health Records potentially including scheduling/practice management systems.”
Caremesh: “To achieve this, the data should be collected electronically from EHRs, which in most cases already record basic user information, such as name, specialties, identifiers, practice locations, and contact details, including Direct Addresses and FHIR endpoints. Furthermore, this should be enforced through a new CEHRT requirement, which will move the burden from CMS itself and providers to the technology companies that support them.”
CVS Health: “We believe that such an approach is necessary to streamline collection of this information and improve its accuracy and allows connections with other data management systems/EHRs, and potentially scheduling/practice management systems.”
Doximity: “We encourage CMS to continue prioritizing automation, data interoperability, and strong governance as it builds this foundational infrastructure. We will continue to support efforts that align with our core mission to make the practice of medicine easier for physicians across the country.”
Epic: “Automated, machine-to-machine communication reduces human error and burden while speeding updates. Automated updates will enable real-time directory data, which is necessary to facilitate workflows like checking if a provider is in-network, or for reliably routing a referral. The directory should prioritize API-based, machine-readable infrastructure over static portals or self-attested files.”
Kyruus: “To achieve this, we specifically recommend that CMS prioritizes the development of neutral and robust national provider directories with comprehensive patient-centric data (TD-2), encourages targeted cost estimation APIs similar to RTPB (TD-19), and supports the creation of a National Provider and Location directory API that includes appointment availability (TD-2-a, TD-2-c).”
SCAN Health: “Require EMRs, payers, and care platforms to support: Automated directory synchronization via FHIR endpoints, Role-based affiliation management for team-based care (e.g., specialists, care managers, therapists), Standardized data elements (location, NPI, network status, languages spoken, virtual availability).”
Surescripts: “A national provider directory must have strong governance for data quality. CMS must prioritize API-based, machine-readable data attestation over manual attestation (web portals, flat files).”
ZocDoc: “To unleash innovation and better support patients and providers, CMS and ONC/ASTP should consider including policies that specifically mandate the availability of APIs for administrative data. This would push for greater interoperability in areas like appointment management, intake forms, and the real-time viewing of providers’ schedules. By treating administrative data similar to how clinical data is handled under information blocking rules, CMS can create a powerful incentive for EHRs to open up access, fostering a more competitive and innovative digital health ecosystem.”

7. Data accuracy is a top concern, even among supporters of a national directory. Many suggest governance and quality controls.

Theme: There was some doubt that a national directory alone would fix deep-rooted directory accuracy issues, especially without strong data governance, provider accountability, incentives, and enforcement. Many organizations offered recommendations on data quality controls to establish within the national directory.

Caremesh: “There is a temptation to include broad and varying data types in an NDH/NPD. However, individual users in every organization need to leverage core directory information, combined with local and specialized information, for their particular use cases. And there are millions of use cases. The hard part is standardizing and inter-relating provider names, credentials, locations, organizations, services, and digital and analog communication addresses. This is where CMS should focus.”
CVS Health: “The success of a national provider directory hinges on the establishment of trusted governance. Without a central, transparent authority to define standards, oversee data accuracy, and ensure accountability, provider information can quickly become outdated, fragmented, or inconsistent across systems.”
Epic: “The first step is validation as data is entered into the directory. CMS should implement data cleanliness checks for updates, such as verifying address formats, taxonomy codes, and deactivation status. FHIR endpoints can be verified on submission and on a rolling basis by ensuring that they are online and accessible. The second step is ongoing attestations from directory participants (individuals, facilities, payers) that information is still current. CMS should use automated reminders to prompt participants to either update their information or attest that it remains accurate. CMS could consider measures to encourage compliance, such as flagging entries and sanctioning actors who fail to meet annual attestation. Finally, CMS should appoint a dedicated directory quality officer to lead a multi-stakeholder panel responsible for defining data quality metrics, conducting audits, offering guidance, and publicly reporting on the quality of data sources and the overall integrity of the directory.”
Kaiser Permanente: “Accurate provider information is integral for patients and consumers to access care. However, provider information contained in existing systems is not reliable because it is not kept up to date consistently, contains inaccuracies, and is not consistent across different systems. We are concerned that these serious challenges will carry forward to future systems if not addressed proactively. We recommend that CMS first focus on ensuring data quality, defining role clarity and responsibilities, streamlining regulatory requirements and establishing accountable governance processes before implementing new infrastructure or interoperability requirements.”

8. A national directory could support credentialing use cases

Theme: Beyond interoperability and patient access use cases, some contemplated a national directory supporting credentialing and payer enrollment. This may require integrations with primary sources and alignment with accreditation bodies who currently oversee credentialing programs.

Availity: “This involves establishing a dataset and collection mechanism that can fuel not only a directory, but also standardized enrollment and credentialing processes.”
BCBS Massachusetts: “A nationwide provider directory could also help to ease administrative burdens associated with on-boarding new providers, which helps to speed building of provider networks in key segments such as primary care and behavioral health.”
Claritev: “Payors would directly benefit from a nationwide provider directory that allows them to quickly obtain accurate data that they can use to validate the credentials and licenses of providers.”
Epic: “Licensing and credentialing bodies are best positioned to update a provider’s
licensing and credentialing status.”
H1: “We also encourage CMS to adopt provider credentialing standards (e.g. using FHIR® R4 Provider resource). In fact, the success of VBC (‘directing the right attention to the right patient’) hinges on this. Healthcare provider organizations, insurers and private sector developers would all benefit from a unified federal standard for credentialing.”
LexisNexis: “Verifiable credentials for providers could enable CMS to establish a national provider directory, reinventing NPI issuance, provider screening, and verification processes. This approach should leverage identity assurance provider screening journeys similar to those used for issuing verifiable credentials to citizens. It could standardize atypical providers at state and national levels.”
Microsoft: “We believe a nationwide provider directory with FHIR endpoints that included provider credentialing information (e.g. signed digital assertions about the states in which a provider is licensed to practice) would be immensely valuable to payers.”
Oscar: “Additionally, including National Committee for Quality Assurance (NCQA) and URAC credentialing information in the required fields could allow payers to automate the credentialing process.”
SCAN Health: “Establish a National Digital Credentialing Exchange. Fund and oversee a centralized, national credentialing verification platform that allows: Providers to upload and maintain verified credentials in one place, Health systems and payers to query and retrieve credentialing data in real time, Leverage existing standards from CAQH, NCQA, and State Licensing Boards.”

9. A wish-list of novel data and use cases for a national directory

Theme: The range of proposed data elements and use cases suggests that a national directory could serve as a foundational utility with far-reaching applications beyond the initially prioritized use cases.

Cleveland Clinic: “Such a directory should include eligibility dates for members and demographics because the foundation of data exchange begins with eligibility verification. Additionally, the directory should provide a comprehensive history of medical and prescription claims for members, even prior to their eligibility start dates, to ensure healthcare providers have a complete understanding of the patient’s medical history. This includes revenue codes, CPTs, and Rx NDCs for each encounter, supporting thorough and accurate claims data analysis.”
H1: “Key data include provider names, specialties (including detailed information on areas of focus and procedures performed), practice locations, network affi liations (in-/out-of-network status), group memberships, availability (e.g. accepting new patients), and credentialing information (licensure, board status), quality and cost measures, and social determinants of health for risk stratifi cation.”
HiLabs: “FHIR API Expansion with AI: Mandate and promote wider adoption of FHIR-based APIs (e.g., FHIR Scheduling, FHIR Questionnaire, FHIR Appointment) beyond clinical data to cover administrative functions. AI models can facilitate the mapping and transformation of legacy administrative data into FHIR standards, reducing the technical burden on EHR vendors and providers.”
Jefferson Health: “A ‘digital yellow pages’ is crucial for innovation by VBC organizations. This would allow for faster development of our data integration, analytics, clinical decision support, disease burden capture, and care coordination programs.”
Leavitt Partners: “Ensure the national health care directory being developed by CMS includes quality measures about individual licensed practitioners and medical practices, follows the Patient Brands and Endpoints sub-specification, and provides updated specialty and sub-specialty codes confirmed by patient complaints. This helps app developers navigate patients/caregivers to the right care.”
New York Urology Specialists: “For a health IT vendor trying to serve thousands or millions of patients across the country belonging to one of more than 88,000 health plans, there is no feasible way to connect electronically to health plans without having an adopted national standard Health Plan ID with detailed information about it’s status, contact information, digital endpoints and legal status. Before attempting a National Provider Directory, CMS/HHS should fix the existing problem, the failure to issue a HPID.”
Oscar: “To achieve a national provider directory, we believe the required information for providers must be inclusive of state specific requirements and not just limited to federal requirements. Otherwise, the quality of the data will be incomplete and payers will still have to seek out alternate data sources and verification processes with providers to confirm the outstanding information.”
ZocDoc: “The Health ACCESS Alliance represents a growing list of 30+ organizations, which include hospitals, health systems, FQHCs, health tech innovators, patient advocacy orgs, trade associations and more. Zocdoc has joined the Health ACCESS Alliance to advocate for common sense modernization through their support for the Health ACCESS (Accelerating Consumer’s Care by Expediting Self-Scheduling) Act, which is a bipartisan, bicameral bill that would create such a safe harbor. This would allow health information services to help Americans, including federally funded beneficiaries, find care more easily, without unnecessary legal uncertainty for the providers that utilize these services.”

10. Existing provider directory API issues need to be addressed

Theme: There was recognition that current provider directory APIs mandated under CMS rules are often broken, nonfunctional, or hard to use. These issues need to be addressed before a national directory is able to ingest data from payers to support interoperability and patient access use cases.

American Hospital Association: “We have several concerns relating to operationalizing the Provider Directory API. For example, some Provider Directory APIs do not fully and accurately represent plan details and networks. For these APIs to be useful to patients, they must be reliable.”
eHealth Exchange: “Existing CMS mandated FHIR Provider and Plan Directory APIs are insufficient, suffering from inconsistent data models, update support, authentication barriers, rate limiting, protracted downtime, and data accuracy issues.”
H1: “We suggest CMS consider ‘API certification’ for private sector provider data services. A voluntary certification or trustmark for high-performing provider directory APIs would set quality benchmarks (accuracy, completeness, timeliness) and encourage adoption of best practices (standard FHIR profiles, USCDI metadata) without duplicating mature commercial solutions.”
The FHIR Department: “With stronger monitoring and enforcement, in-network status and cost estimation could become universally accessible and reliable, improving Provider Directory APIs and Price Transparency files. Standardizing and ensuring completeness of these files would provide accurate patient information, supporting better care navigation and provider competition.”

The Takeaway

The comments submitted in response to CMS’s RFI reflect broad interest in building a nationwide directory, but also underscore that its success will depend on thoughtful execution. Stakeholders emphasized the potential to reduce administrative burden, improve interoperability, and support patient decisions. Many of the same stakeholders cautioned against redundant systems and unchecked provider burden. Several recommended leveraging existing infrastructure, automating data from EHRs, and establishing strong data governance and accountability. Taken together, the responses highlight the opportunity: with the right design and governance, a national directory could become foundational infrastructure for the modern healthcare data ecosystem.