By James Henderson, SVP & GM, U.S., Orion Health
In August 2025, Orion Health shared its intent to support the CMS Health Technology Ecosystem, reinforcing how closely our platform, partnerships, and product direction already align with national priorities for interoperability and patient access. Since then, that alignment has been formally recognized by CMS across key categories, including Data Networks and Patient-Facing Applications.
From a U.S. leadership perspective, this commitment is not a change in direction. It reflects work Orion Health has been advancing for years with hospitals, health systems, and state partners, and makes that alignment more visible to the market. It also signals something equally important: that we are ready to support meaningful outcomes now, not simply plan for the future.
Across these efforts, our focus consistently centers on operational priorities that matter most to healthcare leaders on the ground: patient identity accuracy, governed and auditable data, behavioral health, and continuity of access across care settings.
Starting with Patient Identity
Patient access starts with knowing who the patient is. Accurate identity matching underpins every downstream use of health data, from care coordination and analytics to patient-facing digital experiences.
Our approach to identity management emphasizes configurable matching, transparent confidence scoring, and operational workflows that allow teams to review, merge, and unmerge records as needed. These processes are fully auditable and designed to operate at scale within existing hospital and health system workflows. The objective is straightforward: reduce duplicates and overlays so data follows the right person, every time, and clinicians can trust the record in front of them.
Data Governance and Readiness for Responsible AI
AI is only as trustworthy as the data behind it. For health systems evaluating AI-enabled workflows, confidence depends not just on performance but on governance, transparency, and explainability. Ensuring data is reliable, traceable, and fit for use across clinical and operational contexts.
We prioritize data lineage, consent awareness, and explainability so leaders can understand where data originated, how it was curated and combined, and how insights were generated. Because much of healthcare data remains siloed across systems and settings, responsible AI also depends on bringing together information from multiple sources into a unified, interoperable view; enabling a more complete, whole-person understanding rather than isolated pieces of information.
Protecting Privacy, Including Behavioral Health
Modern interoperability must respect the sensitivity of certain data types, particularly behavioral health and substance use information.
Our platforms support consent-aware access and data segmentation, enabling organizations to protect confidentiality while still supporting appropriate care coordination and follow-up. These capabilities align with evolving regulatory expectations, including those under 42 CFR Part 2, and are designed to function within real-world clinical and operational constraints.
Planning for Continuity and Resilience
Hospitals plan for disruptions because system outages and downtime remain a recurring challenge across healthcare, often forcing clinicians to rely on manual workflows at precisely the moments when continuity matters most. Interoperability should support resilience, not create new risks.
Our focus is on helping organizations maintain access to longitudinal patient information when primary systems are unavailable, with clear recovery processes and auditability once normal operations resume. Continuity of access is not simply an IT concern; it is fundamental to patient safety and operational confidence.
Extending Interoperability to Rural Communities
Interoperability must work not only in large urban systems, but also in rural and resource-constrained environments. In many rural communities, individual facilities face real limitations in staffing, funding, and technical capacity. By working through rural health associations and shared networks, organizations can access capabilities and support that would be difficult for any single facility to sustain on its own.
Orion Health has longstanding experience supporting statewide and regional health data infrastructure, including rural health networks. These environments face unique challenges related to access, scale, and sustainability, making practical, resilient data infrastructure especially critical as CMS priorities are operationalized nationwide.
An Invitation to Co-Design What Comes Next
This commitment to the CMS Health Technology Ecosystem is not a finish line. It reflects how we continue to work with customers and partners to turn policy alignment into operational progress.
If your organization is advancing initiatives related to patient identity, data quality, or continuity of access under the CMS framework, I invite you to engage with our team in a focused discovery session. Together, we can define practical use cases and shared measures of impact that help translate national goals into real-world results.

James Henderson
SVP & General Manager, U.S. at Orion Health
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