On September 21, 2026, the Centers for Disease Control and Prevention CDC published a Request for Information RFI in the Federal Register, seeking broad public input on the role of "data intermediaries" in enhancing secure, scalable, and standards-based public health data exchange. This pivotal initiative, with comments due by November 20, 2026, aims to inform the CDC's evaluation of these intermediaries and explore how they can significantly contribute to preventing disease, detecting emerging threats, and strengthening public health systems nationwide. The agency recognizes that effective public health action hinges on timely, accurate, and actionable data flowing seamlessly across a complex ecosystem of patients, providers, and public health entities.
The Imperative for Modernizing Data Exchange
The CDC underscores that without robust data, public health professionals struggle to identify patterns, assess risks, or develop effective interventions. While significant progress has been made through CDC's data modernization investments, including the Public Health Data Strategy and the One CDC Data Platform, challenges persist. Data inconsistency, siloing, and interoperability issues continue to hamper the speed and precision of public health responses to both chronic and emerging health threats. The RFI emphasizes that addressing these issues requires innovative approaches that build on existing investments to make data more accessible, standardized, and usable across all levels of public health. Data intermediaries, defined as trusted organizations or services facilitating secure, standards-based exchange and stewardship of health-related data, are central to this renewed focus.
Defining Public Health Data Intermediaries
For the purpose of this RFI, the CDC has put forth a working definition of a public health data intermediary as a trusted organization, network, platform, or governed service that enables secure, standards-based exchange and stewardship of health-related data among data sources and public health authorities. These intermediaries are envisioned to reduce connectivity burden and improve the quality, timeliness, and usefulness of data for public health practice, all while safeguarding individual privacy and confidentiality. They may also offer additional services such as analytics, visualization, and technical assistance. The CDC explicitly seeks feedback on how this definition aligns with existing understandings and on-the-ground experiences within public health and health information technology HIT, inviting suggestions for improvements to enhance clarity or alignment.
Potential intermediaries include established entities like Health Information Exchanges HIEs, Health Data Utilities HDUs, and those operating under the Trusted Exchange Framework and Common Agreement TEFCA. The RFI highlights the evolving HIT ecosystem, including the Centers for Medicare and Medicaid Services CMS Digital Health Tech Ecosystem, as creating new opportunities to leverage various intermediary models more effectively.
Establishing Standards and Technical Capabilities
The RFI delves into the technical and operational aspects of data intermediaries, recognizing their diverse functions and maturity levels. The CDC is developing a Public Health Intermediary Framework, which is a layered approach designed to help public health organizations specify, select, and evaluate intermediary capabilities. This framework comprises a universal intermediary baseline, service-specific profiles, and public health use-case profiles. The universal baseline would cover core capabilities and safeguards applicable to any intermediary, while service-specific profiles would address additional expectations based on services provided like aggregation or analytics. Use-case profiles would detail requirements for specific public health programs such as electronic case reporting or immunization data exchange.
The CDC asks for specific input on which capabilities and standards should reside in each layer of this framework, touching on areas such as data quality, exchange and routing mechanisms, security and trust protocols, and operational reliability. Furthermore, the RFI solicits recommendations on how to assess intermediaries against these expectations, including standardized metrics, testing approaches like conformance testing, and the utility of maturity models to advance capabilities over time. A forward-looking question also explores how artificial intelligence AI capabilities might influence the technical, governance, and operational roles of these intermediaries.
Funding and Sustainability for Shared Infrastructure
A critical element of the RFI focuses on the funding and sustainability of shared data intermediary infrastructure. The CDC acknowledges that long-term viability requires financial models that extend beyond initial implementation to cover ongoing operations, maintenance, governance, security, and scalability. The agency seeks public comment on current funding and revenue sources, identifying who bears the costs and who receives the benefits, particularly differentiating between public health specific services and broader shared infrastructure.
The RFI probes for insights into sustainable funding models, factors affecting costs and technical burden, and how funding models can account for varying use cases and benefits across participants. Significantly, the CDC requests examples of current practices that reduce financial barriers for under-resourced entities such as rural providers, small laboratories, tribal entities, and safety-net providers. The agency is also exploring funding and contracting approaches that could promote portability, competition, open standards, and sustainable market participation, while actively avoiding unintended market distortion or vendor lock-in.
Governance Framework Considerations
The final area for public comment concerns the governance framework necessary for the effective use of data intermediaries. Similar to its approach for technical capabilities, the CDC is applying a layered governance model, which includes a universal governance baseline and service-specific governance profiles. The RFI seeks input on principles related to accountability, neutrality, authority, oversight, and equitable implementation. Establishing clear governance is essential to ensure that data intermediaries operate transparently, fairly, and in alignment with public health objectives and privacy protections.
