Comment on CMS-2026-2279-0001

CMS and the ONC need to classify all delegated and downstream entities and subsequent downstream entities, and all subcontractual relationships and delegation (and hopefully as farthest downstream as possible), as first tier FHIR execution actors. Managed Medicaid goes as far down as the subcontractor’s contractor. CMS and the ONC need to assess the number of subcontracted relationships it takes to reach the consumer across Medicare Advantage, managed Medicaid, TPAs, Exchanges, delegated ERISA, the MSSP program, the ACO program, PPO network contracting to assess how far down the operational FHIR execution chain goes. To clarify, this is so that all relevant computable health information is available across the entire operational ecosystem for a completely connected experience. This will help with the development of KPIs for the amount and quality of the subcontractual relationships and further downward delegates for consistently computable interoperability of FHIR APIs for a consistent semantic and executable infostructure. The below types of entities shall be first class FHIR execution actors and use the latest FHIR IGs at scale: •All sub-delegates with sub-delegated functions •All entities involved in subcontractor network certification •All delegated subcontractors •All partially delegated subcontractors •All subcontractors and downstream subcontractors Computable contracting with the FHIR Contract resource would be helpful to model •Ultimate owner (examples may be investment firm or holding company) •Legal contracting entity: the entity which signs the agreement •Operating entity •Risk bearing entity •Data holder/Data controller •Delegated entity (contracted functions) •Downstream entities (subcontracted functions) •Further downstream entities (subcontractor’s subcontracted functions)