A Clear Path Forward for Plans Evaluating the Pledge
In July 2025, CMS officially launched the Health Tech Ecosystem — and within months, more than 700 organizations pledged participation, including every major national insurer. The infrastructure for a new era of interoperability is no longer hypothetical. It is live, it is growing, and it is reshaping how plans compete for members, providers, and quality ratings.
This guide is written for health plan leaders evaluating whether and how to participate in the CMS Payer Pledge. It explains what the pledge is, who has already joined, what the eight baseline capabilities require, and what implementation looks like once a plan commits.
In this guide we break down:
- What is the CMS Payer Pledge?
- Timeline and CompetitiveStakes
- Who Has Pledged
- Why Pledge and Why Now
- The Eight Baseline Capabilities
- Operational Criteria and Implementation
- How to Meet the Pledge
What Is the CMS Payer Pledge?
The CMS Tech Ecosystem Payer Pledge is a public commitment by health plans to participate in a new national interoperability infrastructure. This universal standard makes it seamless for patients, providers, and payers to share health data without friction, portal logins, or proprietary workarounds.
By pledging, payers commit to meeting seven core capabilities that enable real-time, standards-based data exchange across the care continuum. The pledge signals to CMS, providers, members, and the market that your organization is operationally ready for the next generation of healthcare data exchange.
The Race Is On
The CMS Tech Ecosystem launched fast, and the competitive clock is already running.
What’s coming:
- Quality measure reporting guide for payers and providers
- Expanded Implementation Guide requirements for payer-to-payer data exchange
- Ecosystem participation tied to reporting and measurement frameworks
- Provider-side mandatory participation timelines
- Patient-facing apps accelerating demand for payer responsiveness
The window for early-mover advantage is open, but it is closing. Plans that pledge now shape the ecosystem. Plans that wait must then comply with what others built.
Who Has Pledged
The largest health insurers in the United States are already inside the ecosystem. UnitedHealthcare, Aetna, Elevance, Cigna, and Centene have all pledged. On the provider side, major health systems and digital-first plans including Oscar Health and Clover Health have committed as well. CMS Blue Button v3.0 is also live using modern identity (IAL2) instead of a portal login.
The foundational players have set the stage for the future.
Why Pledge — and Why Now
Regulatory Alignment
CMS has made interoperability a central enforcement priority. Pledging positions your plan ahead of mandates rather than scrambling to meet them. Plans that act early avoid the disruption of reactive implementation and demonstrate compliance readiness.
Competitive Positioning
Plans inside the ecosystem gain visibility in provider and patient-facing directories. Plans outside it are invisible. Every week without a pledge is a week competitors are building discovery, data, and relationship advantages that will be difficult to overcome.
Member Experience
Members access their complete health record — claims, EOBs, prior authorizations, clinical data — through any Medicare App Library, without calling member services or navigating portals. This reduces friction, increases satisfaction, and builds the trust that supports retention and star ratings.
Supplemental Data Access
By joining a CMS-Aligned Network, payers can query clinical data outside their own systems — encounter data, lab results, and quality measures from across the network. This strengthens risk adjustment, closes care gaps, and supports quality reporting in ways that payer-only data simply can’t.
The Eight Baseline Capabilities
Eight MVP capabilities define a payer’s baseline participation in CMS-Aligned Networks. Each capability is required to respond to patient, provider, and payer queries through the network. Here is what each requires and exactly how b.well delivers it.
1. Claims & Clinical Data Sharing
What it requires: Respond to patient, provider, and payer queries for claims and clinical data without portal accounts.
Why it matters: This is the foundational obligation. Any credentialed party — a patient, a treating provider, another payer — can request data, and you must respond.
How b.well delivers: b.well streamlines and brokers query and response on the payer’s behalf across all three channels via FHIR APIs. No need to design and build the pipes — just connect to ours.
2. Clinical Data Query
What it requires: Query providers for clinical data tied to claims submitted in the prior 60 days for adjudication or quality purposes.
Why it matters: This is where the supplemental data advantage lives. Payers can pull clinical context they were never able to access before, closing the gap between what was billed and what actually happened clinically.
How b.well delivers: b.well enables payer-initiated queries that return clinical data for both claims adjudication and quality measure reporting, including HbA1c values, mammogram completion, blood pressure, BMI, and depression screening results.
3. Quality Measure Data Query
What it requires: Query providers for clinical data elements needed to calculate and report quality measures, including HEDIS metrics, independent of claims adjudication.
Why it matters: Quality reporting drives Medicare Star Ratings, value-based contracts, and care gap closure. Payers who can query for clinical data in real time — rather than relying on retrospective reporting — can identify and close gaps before they become costly, and report with far greater accuracy.
How b.well delivers: b.well automates quality measure calculation using Clinical Quality Language (CQL) and NCQA’s Digital Content Services, pulling real-time data directly from EHR and payer systems. Rather than recreating measures manually each year, b.well delivers digitized HEDIS measures that run continuously against longitudinal health records. This enables payers to identify care gaps proactively, upstream, before members fall behind on care.
4. National Provider Directory
What it requires: Create, maintain, and submit provider and payer directory entries that include organizations, locations, endpoints, and verification metadata.
Why it matters: The NPD is the trust backbone of the ecosystem. Accurate directory entries are how your plan gets found and how identity verification works across the network.
How b.well delivers: b.well enables payers to interact with the NPD directly or through b.well’s managed participation, removing the burden of maintaining real-time directory infrastructure in-house.
5. Patient Matching
What it requires: Use CMS-approved matching logic. If an incoming query matches any of the 27 approved identity combinations, the payer must respond.
Why it matters: Poor matching means data doesn’t reach the right person — or worse, reaches the wrong one. CMS requires a defined and validated standard approach, not a proprietary one.
How b.well delivers: b.well’s Master Person Index (EMPI) with probabilistic matching and Record Locator Services (RLS) ensures your plan reliably identifies and responds to incoming queries using CMS-approved logic.
6. Identity & Trust
What it requires: Participate in the NPD for endpoint and identity verification. Publish query endpoints and contact metadata so other network participants can reach you.
Why it matters: Trust in the ecosystem depends on verified identities and reachable endpoints. This is how the network knows who is asking and whether they are authorized.
How b.well delivers: b.well has deep expertise in IAL2 management and seamlessly handles identity and trust participation on the payer’s behalf, including endpoint publishing and ongoing verification.
7. Patient Access (IAL2)
What it requires: Support patient access to claims and clinical data using CMS-approved IAL2 credentials. No portal login can be required as a condition of access.
Why it matters: This removes the gated, friction-heavy model most payers have relied on for member data access. If the member has an IAL2 credential, they get their data.
How b.well delivers: b.well provides customizable Patient Access support built around each payer’s specific requirements, supporting IAL2 credential verification and data delivery without forcing members through portals.
8. Auditability
What it requires: Maintain audit logs of all data requests and responses for patient-facing transparency.
Why it matters: Members have a right to know who has accessed their data and when. This is both a trust requirement and a compliance obligation.
How b.well delivers: b.well provides HITRUST-certified audit logs of every data request and response, with complete data traceability, for member transparency and regulatory review.
You don’t need to build your way into this ecosystem. Just connect to it.
b.well is a designated CMS-Aligned Network and is leading the early-adopter working group authoring the Implementation Guides for Patient Access, Payer Access, and Provider Access. Our platform is FHIR-native, CMS-validated, and built on the exact standards the pledge requires: FHIR R4, USCDI v3, Patient Access API, and Provider Access API.
When you connect to b.well, query brokering, patient matching, identity verification, encounter notifications, and audit logging are all handled on your behalf from day one.
Once You’ve Pledged: Be Ready to Implement
Pledging is the initial commitment. Below are the operational criteria your plan must then honor to participate fully in the ecosystem.
Patient Data Access
- Members can access claims, EOBs, prior authorizations, and clinical data from current and past payers
- Patient access extends across all electronic medical information the payer holds, with only limited exceptions, for both structured and unstructured data
Identity and Authentication
- When members present IAL2/AAL2 credentials, return data without portal logins or extra verification steps
- Leverage supplemental credentials, including digital insurance cards, to strengthen identity verification
- Accept requests from any app in the Medicare App Library — no special status required for the requesting app
Provider Access
- When a provider presents IAL2/AAL2 credentials and attests to treatment purpose, return all permitted patient data
- Accept transactions from a provider’s chosen technology partner under a BAA
Quality and Care Gap Queries
- Query for quality data elements including HbA1c, mammograms, blood pressure, BMI, and depression screening
- Query for clinical data tied to claims submitted within the last 60 days
Connect to b.well. Meet the Pledge. Lead the Market.
The CMS Tech Ecosystem opens a new frontier for payer data strategy. Your plan can access richer clinical data, engage members more meaningfully, and deliver the kind of seamless digital experience that drives real health outcomes.
b.well is the only CMS-Aligned Network that is simultaneously a pledge participant, an Implementation Guide author, and a full-stack digital health platform. We bring together the infrastructure, certifications, standards expertise, and member experience so your plan can move from pledge to live participation without standing up new engineering capacity.
Our platform is live. Our certifications are current. Our Implementation Guide contributions are shaping how the ecosystem operates.
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