Why CMS’s Digital Health Push Risks Leaving Social Care Behind

I’m truly excited by the support for accelerating healthcare interoperability, an effort that can have a significant impact if executed correctly. However, I have some serious concerns about the recent White House CMS tech summit, “Making Health Technology Great Again,” and its approach to digital health.

The summit aimed to advance a patient-centered digital health ecosystem, interoperability, and health IT adoption, building on standards like TEFCA and HL7 FHIR. The CMS Interoperability Framework, supported by the MAHA Presidential Order 14212 and HHS MAHA Report, proposes private-public partnerships, focusing on patient empowerment, burden reduction, expanded data sharing, and security. The blueprint for this is the Leavitt Partners’ “Kill The Clipboard” white paper (Feb 2025).

My primary concern is the disproportionate focus on clinical data while largely neglecting non-clinical social care data, also known as health-related social needs (HRSN) or social determinants of health (SDOH). HRSN can account for up to 50% of health outcome variations, compared to 10-20% for clinical care. True “whole patient care,” a MAHA mission, must address both.

Excellent work is already underway in social care data standards by initiatives like the Gravity Project and Direct Trust, summarized in the “Social Care Co-Design Final Report” (May 2024). Comparing this report with the MAHA report and the CMS Interoperability Framework reveals key issues:

Key Issues and Gaps

• Language and Terminology Barriers: The Social Care Co-Design report highlights distinct vocabularies across social work, healthcare, and disability services. The “Kill the Clipboard” report, however, is healthcare-centric, focusing on EHRs, FHIR APIs, and clinical interoperability, largely ignoring social care terminology.
• Power Imbalances and Resource Disparities: The Gravity Project found significant power imbalances and underfunding for social care providers, limiting their participation in data sharing. The CMS summit included tech giants and major health systems, but seemingly no community-based social care organizations.
• Divergent Approaches to Social Determinants:
  • Healthcare (CMS/Leavitt): Data-driven, technology-first, individual patient focus (APIs, digital infrastructure, personal health records).
  • Social Care (Co-Design): Relationship-centered, community-focused, rights-based (human connection, population-level interventions, social justice).

Specific Gaps in the CMS/Leavitt Approach

1. No Social Care Data Standards: The “Kill the Clipboard” report lists 25+ healthcare-focused APIs (e.g., prior authorization, patient cost), but lacks APIs for crucial social care areas like housing stability, food security, or employment support.
2. Technology Assumptions: The CMS approach assumes robust IT infrastructure and digital literacy for all. The Social Care Co-Design reports reveal accessibility barriers, resource constraints in community organizations, and trust issues among vulnerable populations.
3. Missing Stakeholder Voices: Attendees at the CMS pledge meeting were primarily tech companies, health systems, and EHR vendors. Critical voices from community health centers, housing authorities, food banks, and social service agencies were absent, despite the Co-Design report emphasizing their essential participation.

Potential Failure Points

• Data Integration Challenges: Healthcare data is structured, while social care data is often unstructured and contextual, making FHIR schema integration difficult.
• Different Success Metrics: Healthcare focuses on clinical outcomes and cost reduction; social care prioritizes quality of life, community stability, and empowerment.
• Regulatory Misalignment: CMS efforts consolidate under a single agency, but social care funding comes from various federal and state departments (HUD, USDA, DOL).

The documents reveal a fundamental disconnect. While the Gravity Project identified these challenges, its solutions have focused more on technical standards than on power imbalances and funding. The Social Care Co-Design work highlights the need for cultural change and respectful relationship building. The CMS initiative risks improving healthcare efficiency while inadvertently widening the gap in whole-person care.

Recommendations for Success

To truly “Make Health Technology Great Again” and achieve comprehensive interoperability, the initiative must:

• Include social care organizations as equal partners in governance and standard-setting.
• Address funding disparities for social care providers.
• Develop social care-specific APIs to capture community-based data.
• Create cross-sector terminology standards that respect both healthcare and social care perspectives.
• Prioritize relationship-building alongside technical integration.

Without addressing these fundamental differences in approach, resources, and perspective, the ambitious CMS digital health transformation may fall short of its “whole patient care” goal.