Particle Health’s Policy Platform: Building a Foundation for Healthcare Data Abundance

The Centers for Medicare & Medicaid Services recently completed a Request for Information on the digital health ecosystem, seeking input on how to advance true healthcare interoperability. Particle Health sits in the middle of this ecosystem and we welcomed the opportunity to participate. 

Today, Particle connects healthcare organizations to over 320 million patients’ medical records from more than 70,000 healthcare organizations. Our policy platform centers on a fundamental truth: healthcare must transition from an era of data scarcity to one of abundance. If we fail to do so, the only winners are entrenched corporations who will continue to exploit their data and access monopolies. Particle Health is actively working to catalyze this shift and is advocating for policy frameworks that support it. While significant progress has been made through the development and adoption of TEFCA and the 21st Century Cures Act, structural barriers continue to lead to fragment patient care while limiting innovation. These barriers directly impact providers’ ability to deliver timely and effective care and patients’ ability to access their own health information.

Particle Health’s policy recommendations identify three immediate actions that will accelerate the transition from scarcity to abundance. 

• First, existing information blocking rules need proactive, centralized enforcement through the Recognized Coordinating Entity (RCE), with clear consequences for non-compliance. Current QHIN-based, self-policing mechanisms have proven inadequate, allowing selective disclosure and non-responsive endpoints to persist with virtually no accountability. 
• Second, QHINs must be barred from imposing excessive administrative requirements that don't enhance patient privacy or data security, particularly those that create undue burdens for smaller practices and Integrated Delivery Networks. 
• Third, TEFCA requires clear, mandatory timelines for responding to operational and Individual Access Services queries, with associated penalties and enforcement mechanisms.

These recommendations stem from our daily experience enabling data exchange across the healthcare ecosystem. We've witnessed firsthand how information blocking tactics—from non-responsive endpoints to deliberately unusable responses—undermine the care that patients deserve. We’ve also seen the potential when data flows freely and securely: more accurate diagnoses, better care coordination, reduced readmissions, and improved outcomes for vulnerable populations.

We hope industry peers, policymakers, and healthcare leaders will read our response and consider how these policy changes could benefit their organizations and the patients they serve. Fellow healthcare leaders take the initiative to engage with representatives and CMS directly. Together we can educate and advocate for the enforcement mechanisms and policy implementations that will deliver on the promise of true healthcare interoperability.

Read our complete response to understand how targeted policy reforms can accelerate the transition from healthcare data scarcity to abundance, making sure that all qualified organizations have access to the information needed to improve patient care.

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