Digital Health Briefing - Dec 15 - Dec 21, 2025

Dec 15 - Dec 21, 2025

36 articles analyzed

Executive Summary

Federal regulators have moved to end 'rent extraction' in health data exchange by capping EHR vendor fees at cost recovery. Concurrently, a new push for granular patient consent is forcing major EHR providers like Epic and Oracle to roll out data-control features in 2025, while digital-first care models are demonstrating massive cost-savings through a 58% reduction in surgical rates.

Key Takeaways

Halt revenue-sharing arrangements for health data access: ASTP/ONC guidance now prohibits EHR vendors from charging fees for EHI access that exceed actual cost recovery. Source
Prepare for patient-led data redaction: Following pressure from Senator Wyden, major EHR vendors will launch granular consent tools in 2025, allowing patients to opt out of cross-organization record sharing. Source
Shift musculoskeletal (MSK) strategy to digital-first models: New data shows digital programs reduce surgical risk by 58%, providing the necessary ROI evidence for payers to move away from in-person physical therapy. Source

Key Themes

Major trends and developments identified from this week's coverage

Data Interoperability Governance

Federal policy is maturing from simply moving data to enabling individual governance and capping the costs of that movement.

ROI-Driven Digital Care Adoption

Digital-first platforms are now producing large-scale claims data to prove significant reductions in high-cost clinical interventions like surgery.

Regulatory and Scientific Fragmentation

Contradictory signals from federal agencies—pushing for AI adoption while questioning vaccine approval standards—are creating a volatile environment for clinical compliance.

Regulatory & Policy Updates

CMS/MEDICARE

ASTP/ONC caps EHR interoperability fees at cost recovery

Ends 'rent extraction' models where EHR vendors charge royalty or revenue-sharing fees for data access, lowering costs for high-volume analytics apps.

FDA

Internal FDA rift over vaccine trial standards goes public

Proposed shifts away from immune markers toward large placebo trials could make childhood vaccine development economically unviable for pharma manufacturers.

LEGISLATIVE

HHS issues RFI to accelerate clinical AI adoption

Establishes a 60-day window for developers and health systems to influence future federal AI reimbursement and regulatory frameworks.

Technology & Innovation

Digital physical therapy reduces relative risk of surgery by 58%

Validates digital MSK programs as a superior cost-containment tool compared to traditional in-person physical therapy models.

CMS-Aligned Networks prioritize automated encounter notifications

Moves interoperability beyond 'viewing records' to real-time, automated workflow triggers that decrease administrative burden for care managers.

AI scribe critique warns of 'mechanized' clinical care

Highlights a growing physician resistance to AI tools that prioritize structured data entry over relational and intuitive patient care.

Market & Competitive Intelligence

Steve Paul's Schizophrenia Spinout

Funding

Third Rock Ventures led a $165M round for a schizophrenia-focused spinout, indicating strong venture appetite for specialized neuro-therapeutics despite broader market caution.

Affordable Care Act (ACA) Marketplaces

Market Entry

ACA premium hikes are imminent as enhanced subsidies expire; exchange directors report enrollees are already shifting to high-deductible bronze plans to avoid cost increases.

What to Watch

HTI-5 Rule Implementation

Q1 2025

The HTI-5 rule is expected to de-certify dozens of legacy EHR criteria, forcing vendors toward modern API-forward standards.

Granular Patient Data Redaction

Late 2025 rollout

Epic and other vendors will launch MyChart features allowing patients to redact specific data from being shared cross-organizationally.

ACA Premium Subsidy Resolution

Q1 2025 legislative session

Ongoing congressional debate over subsidy extensions will determine if millions of ACA enrollees churn or remain in current plans.

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