Our Health Data Center of Excellence (HDCoE) Signal series helps connect current developments in health data with practical leadership decisions. This edition looks at the US Centers for Disease Control and Prevention’s (CSC) RFI on public health data intermediaries and how organizations can assess what one service is able to demonstrate.

Signal — CDC seeks input on a layered framework

Orion Health’s editorial recommendation is clear service scope, accountable ownership, evidence of performance and a sustainable operating model. CDC is seeking input on how intermediaries should be evaluated and has not set a new standard through this RFI.

CDC’s request for information on public health data intermediaries explores a possible shared baseline, additional expectations for particular services and expectations tied to public health use cases. It includes health information exchanges (HIEs) and health data utilities (HDUs) among organizations that could serve this role. Comments are due Nov. 20, 2026.

Separately, CDC’s 2026 Public Health Data Strategy milestones include a target to establish minimum functional requirements and standards for intermediaries and pilot their application in at least five jurisdictions. This is a stated target; the milestone page does not establish that the pilots are complete.

Interpretation — Clear service commitments support leadership decisions

For HIE and HDU leaders, our interpretation is that this discussion has practical consequences for planning and partner agreements. A broad description of network capability may leave partners unclear about what a particular service delivers. Leadership needs enough detail to judge whether staffing, funding and responsibilities match the commitments being made.

CDC’s data intermediary RFI FAQ confirms that this is information gathering, with no new requirement, funding opportunity or procurement. Leaders can use the questions now to identify commitments that need clarification with public health partners.

Implication — Assess one public health service

We recommend starting with one public health service your organization already supports. Bring its operational, technical and public health owners together to document four things:

  • Service scope – Identify the workflow, intended users and boundaries of responsibility. Separate capabilities operating today from those still planned.
  • Performance evidence – Agree on a small set of useful measures, such as delivery timeliness, completeness and time to resolve errors. Establish a baseline before claiming improvement.
  • Accountability – Record who can authorize changes, investigate failures and resolve disputes. Check that the service description matches the agreements and practices governing it.
  • Operating costs – Identify recurring staffing, maintenance and support needs, who pays for them and which assumptions need revisiting.

Orion Health suggests this four-part assessment exercise to help leadership identify gaps between the promised service and the available evidence. This will help surface questions worth raising with your public health partners.

If your organization is considering an RFI response, use that assessment to identify concrete experience you can share publicly and service commitments that need clarification. Your response can help shape the CDC’s work.

Because comments will be posted publicly, do not include PHI, PII, or proprietary information in an RFI response. See CDC’s guidance on public RFI submissions for details.

Primary sources — checked Oct. 29, 2026