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The U.S. Centers for Medicare and Medicaid Services (CMS) recently hosted its “HealthTech Ecosystem Live! First Wave” Launch, during which the agency announced the first apps that it is recommending to Medicare through the Medicare App Library. CMS is continuing to review and planning to add more apps to the Library that are focused on three initial use cases: (1) patient intake forms and processes, (2) conversational AI assistants, and (3) support for diabetes and weight management. Companies that have developed potentially eligible apps or work in related fields may want to consider applying to be listed in the Medicare App Library.
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As of May 8, the Library lists four approved apps and nine that it describes as “almost ready for Medicare.” CMS has encouraged developers to join by promising, among other things, “access to 68+ million Medicare enrollees,” “[n]egotiated identity verification pricing through ID.me and CLEAR, due to CMS's favorable rates,” and “[a]ccess to CMS infrastructure, including the CMS Aligned Networks and modern identify services on Medicare.gov.”
According to CMS, the primary goals of the Health Tech Ecosystem, which was announced last July (as we previewed in a podcast online here), are to improve data interoperability and patient access to health information, as well as increase the availability of digital health and AI tools through partnerships with the private sector. Another core piece of the Health Tech Ecosystem initiative is the “Interoperability Framework,” which CMS describes as “a voluntary blueprint for modern health data exchange that puts patients and providers first.” CMS specifies that the framework is not “intended to create new regulatory burdens” nor “contravene federal and state healthcare and privacy laws.” Rather, the framework is focused data sharing and patient access “principles.” The CMS website notes, however, that technical specifications and implementation guides may be “determined by the working group of early adopters” who have signed the CMS pledges, which are described in more detail below.
Prior to the launch event, the Health Tech Ecosystem, appeared to be largely focused on soliciting “pledges” from various actors in the healthcare and digital health space, with pledge categories that include “Data Networks,” Electronic Health Records,” “Government,” “Health Systems and Providers,” “Payers,” and “Patients/Caregivers.” On May 5, 2026, CMS announced a new pledge category for “Electronic Prior Authorization.”
Each “Pledge” is two to five sentences and appear to largely aspirational and relatively flexible. For example, the “Patient Facing Apps – Diabetes and Obesity” pledge states:
We pledge to connect to CMS Aligned Networks or personal health apps and, with patient consent, securely access relevant health data to deliver personalized support. Our diabetes and obesity tools will use this history to provide tailored guidance—offering direct assistance when appropriate and directing patients to care from a health professional when needed.
Organizations that do not want to sign an industry-specific pledge can sign a “Friend of the Ecosystem” Pledge, which states: “While we are not able to completely meet one of the Health Tech Ecosystem pledges alone, we pledge to work alongside pledgees to provide support, feedback, and/or technology that assists pledgees in successfully delivering on their pledge.” To date, more than 700 organizations pledged support to the ecosystem.
The Health Tech Ecosystem initiatives are voluntary and do not affect any existing rules or payment structures or change the fundamental data privacy, security, and compliance issues facing providers, payers, digital health companies, and patients. Therefore, questions remain over whether and how these initiatives will incentivize healthcare providers to adopt the new technology.
CMS has introduced other new programs directly focused on the improved use of digital health tools to support patient care. For example, in December, CMS launched the ACCESS (“Advancing Chronic Care with Effective, Scalable Solutions”) voluntary payment model, which will test an outcome-aligned payment approach in Medicare to expand access to new technology-supported care options; we described that pilot at the time online here. CMS said it expects that ACCESS participants will “offer integrated, technology-supported care,” including digital technologies such as telehealth, wearables, and apps. To be considered for the model's first performance period beginning July 5, 2026, applications must be submitted by May 15, 2026. Other CMS efforts to encourage the use of digital health tools include Promoting Interoperability Programs and the $50 billion Rural Health Transformation Fund, which CMS has said should be used to “strengthen cybersecurity and interoperability; and expand telehealth, remote patient monitoring, and digital tools that enable timely access to care,” among other purposes.
The use of AI-enabled systems that collect, store and/or process sensitive personal data, particularly health information, trigger important privacy and cybersecurity concerns. To manage risks appropriately, health tech companies must ensure appropriate data governance processes are in place to secure the data and protect patient privacy.
CMS said it expects full implementation of Health Care Ecosystem applications by July 4.
Authored by Melissa Bianchi and Lindsey Johnson.
DigiCure: Legal insights at the intersection of Technology and Life Sciences and Health Care. This article is the 26th in our series, “DigiCure: Legal insights at the intersection of Technology and Life Sciences and Health Care,” which aims to help you stay informed about the broad array of legal and regulatory issues affecting companies operating at the intersection of the technology and life sciences & healthcare sectors. From using AI in clinical studies, to evolving patient data concerns, to the entire digital health product lifecycle, our team will discuss novel issues arising in all parts of the world, including unique deal-making, litigation, and compliance concerns. Ensure you are subscribed to Our Thinking to receive these new insights!