By Scott Brown, President & CEO
Last week, CMS announced the creation of the Office of Health Technology and Products (OHTP), a new office focused on healthcare technology modernization, digital products, interoperability, and what CMS repeatedly describes as “national healthcare infrastructure services.”
While the announcement title might lead a reader to believe it’s just another federal organizational update, I believe the text signals a foundational shift in CMS’s approach to the technology underlying our national healthcare system.
The language reflects a growing recognition that healthcare technology is no longer just about isolated systems or individual applications. CMS increasingly views healthcare technology as infrastructure: foundational support for care coordination, access, interoperability, and continuity across the healthcare ecosystem.
The announcement emphasizes CMS’s modernization strategy, API-based interoperability, FHIR-enabled exchange, identity and trust services, provider- and beneficiary-facing infrastructure, and patient-centered digital access. It also highlights scalable, reusable platforms that support providers, states, payers, and beneficiaries across programs and care settings.
That shift matters.
Healthcare delivery has become far more distributed and fluid than it was even a decade ago. Medicare and Medicaid beneficiaries routinely move across hospitals, physician practices, post-acute care settings, home health, hospice, and behavioral health providers. Critical information has to be able to follow them across those transitions.
This is one of the reasons we’ve consistently viewed advance care planning (ACP) as an infrastructure challenge, not simply a documentation or a “checkbox” challenge.
Care planning conversations and the creation of ACP documents like advance directives and portable medical orders are critically important, but so is ensuring the decisions or documents resulting from those discussions remain accessible when and where they’re needed. Information that can’t be located or accessed during a transition of care or emergency can’t support person-centered decision-making, and it certainly can’t move the needle on reducing unwanted, non-beneficial treatments and interventions.
For decades, the healthcare industry has approached ACP through disconnected workflows tied to individual organizations and local registries. But patient wishes don’t exist within the boundaries of a single care setting. To be effective, they must remain accessible across the continuum of care.
That requires interoperability.
It requires longitudinal accessibility.
It requires identity and trust frameworks.
It requires query and retrieve capabilities.
Increasingly, it requires infrastructure-oriented thinking.
To be clear, the CMS announcement doesn’t specifically reference ACP, nor should it be interpreted as a direct policy initiative related to ACP. But many of the broader themes reflected in the new OHTP structure align closely with conversations already taking place across healthcare regarding interoperability, digital ecosystems, and connected care infrastructure.
We’re already seeing this shift in discussions with states, HIEs, providers, EMS, and health plans that are looking beyond isolated ACP programs and toward more connected, scalable ecosystem approaches that facilitate secure data access and exchange across care settings, as well as the capture of discrete data to support quality measures.
Organizations that focus on interoperability, accessibility, and patient-centered information exchange will be far better positioned going forward than those that continue treating critical healthcare information as disconnected local workflows.
Advance care planning is ultimately about ensuring that people’s wishes can be known and honored wherever care is delivered. But ACP isn’t solely a patient engagement or quality initiative. It’s also a foundational component of Medicare and Medicaid program integrity infrastructure.
About the Author
Scott Brown is President and Chief Executive Officer of MyDirectives, the leader in digital advance care planning. He co-founded the company in 2007 and has led its growth as a nationwide platform for documenting and sharing care preferences across healthcare settings. A strong advocate for interoperability and person-centered care, he is a co-editor of HL7 implementation guides for advance care planning and a reviewer of C-CDA standards, helping ensure care preferences are accessible and actionable at the point of care.
About the Author
Before founding MyDirectives, Scott practiced international corporate, securities, and mergers and acquisitions law in Paris and Dallas.