Dear Mehmet

HTD's letter in response to the CMS RFI

Dear Mehmet,

I write to you from the battlefield of healthcare technology, where the forces of fraud and innovation clash daily. Our consultancy has witnessed the full spectrum of this conflict - from the devastating cyberattack on Change Healthcare to the ghost networks that haunt our provider directories like spectral armies.

The enemy takes many forms: fraud through deliberate deception, waste through careless mismanagement, and abuse through practices that violate our sacred medical standards. These three horsemen ride together, each strengthening the others, draining our resources like a prolonged siege.

But I bring hope from the front lines. We propose three strategic offensives:

First, we must establish digital identity as our foundation - Know Your Business, Know Your Provider, Know Your Customer. Every soldier in this healthcare army must be verified, from the grandest hospital to the humblest patient.

Second, we must build digital networks to replace our antiquated communication lines. No more shall we rely on telegraph-like faxes and exhausting telephone calls. TEFCA or other networks must become our railways, connecting every outpost.

Third, we must liberate patient data from its current bondage. Patients deserve full command over their medical records, able to direct their information wherever duty calls.

Time is of the essence. Our forces have the mandate and the moment. We must act decisively, for half-measures will only prolong our suffering.

I remain, your faithful servant in the cause of healthcare transformation,

Brendan Keeler
Interoperability Practice Lead
HTD Health

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If I was not a complete coward, that would have been HTD’s comment letter. We’re seeing an incredible variety of formats and pitches, so I was convinced old timey Civil War letter format was in the cards. Alas, I’m told by trusted friends it’s “not professional enough” and “might undermine our credibility with regulatory bodies." I responded “big players make big plays” and “shooters shoot”, but was overruled.

Regardless, the CMS Request for Information period has come and gone, so I wanted to make sure to share the thoughts we had at HTD at this critical time. There’s strong alignment up and down (and across) the various agencies involved in healthcare (it’s telling when we’re getting tripartite action done), so we have the chance to effect real change and progress.