PRIME MEMBER EXCLUSIVE | 3 Months Free Trial

Auto-renews at INR 199/mo after 3 months. Cancel anytime. Offer ends 15 July, 2026.
The Information Exchange cover art

The Information Exchange

The Information Exchange

Written by: HTD Health
Listen for free

A not-a-podcast video series about health tech's chess moves and the bigger picture for tech as a whole. Brought to you by the HTD Health team

healthapiguy.substack.comBrendan Keeler Hygiene & Healthy Living
Episodes
  • The Information Exchange: Hot Dog CarePlan Resource Edition

    The Information Exchange: Hot Dog CarePlan Resource Edition
    Jul 4 2026
    Fresh off that sweet, sweet USA win and headed into the long weekend, the full crew assembled for our most patriotic episode yet. Have you ever yearned for a podcast with Fourth of July interop trivia? Look no further, friend.Beyond that, we do (eventually) get to the real agenda:* The ONC awarded a TEFCA auditing contract to Alliance Global Tech, a DC contracting firm nobody in the health tech bubble had heard of. * We work through what the contract actually covers, why the RCE was probably as surprised as everyone else, and whether an outside auditor with no industry baggage is a feature or a bug. * Along the way we review AGT’s website redesign, which traded glorious 2000s-era stock-photo patriotism for AI slop on the eve of the country’s 250th birthday.From there, predictions. Does information blocking enforcement land by end of year? Who gets hit first? Plus Brad’s corp dev forecast for a pre-midterms consolidation rush, year two of the CMS Health Tech Ecosystem, and what HTI-6 might absorb from the pledge-a-thon.Fair warning: none of us are lawyers and none of this should be construed as legal advice. There is, however, a defensible argument that a hot dog is a medication. As promised:{ "resourceType": "CarePlan", "id": "hot-dog-care-plan", "status": "active", "intent": "plan", "title": "Hot Dog Care Plan", "subject": { "display": "Joey Chesnut (DOB 1983-11-25)" }, "period": { "start": "2026-07-04", "end": "2026-07-04" }, "activity": [ { "detail": { "kind": "NutritionOrder", "status": "scheduled", "code": { "text": "Hot dog (frankfurter), oral route. OMD in HL7v2, NutritionOrder in FHIR, a nurse and a side web panel in reality." }, "dailyAmount": { "value": 70.5, "unit": "hot dogs", "system": "http://unitsofmeasure.org", "code": "{hot_dogs}" }, "description": "Ask upon order entry: what do you want on it? Mayo permitted for documented sickos only. Fax to hot dog guy." } }, { "detail": { "kind": "ServiceRequest", "status": "scheduled", "code": { "coding": [{ "system": "http://hl7.org/fhir/sid/icd-10-cm", "code": "Y93.G2", "display": "Activity, grilling and smoking food" }] }, "description": "Pursue Y93.G2. Do not pursue W39.XXXA (Discharge of firework, initial encounter). Ask Jason Pierre-Paul." } } ], "note": [{ "text": "Supportive therapy: one schnatton of water per hot dog. UCUM does not define the schnatton. Neither do we." }] }Let’s dig in. Relevant Articles* Murica: The European mind cannot even begin to comprehend* June Monthly Review: The Unusual Suspect: The full writeup on Alliance Global Tech, from the contract record and credential wall to the case studies that are secretly job postings.* Outgoing Diet Orders HL7v2 Specification: Receipts for the hot dog segment. Diet orders are real, and there's an interface for them.* The Information Exchange: The TEFCA Report Card: Last time we graded TEFCA itself; this week the network got a new proctor.* SEC Budget: Government agency, not the NCAA conference. Actually $1.9 billion.* The Arena Expands: Abridge's land grab across the clinical copilot jobs to be done, background for Brad's consolidation prediction.* The Shape of 2026: Circling back on some HTI-6 predictions Chapters* Intro and the Most American Standard (0:00 – 4:01): Fourth of July interop trivia. Brad nominates fax, Ryan makes the melting-pot case for CCDA, and Pryce disqualifies HL7 on governance grounds.* Prescribing a Hot Dog (4:01 – 8:43): Pryce builds a SMART app for condiment selection, Brad gets caught Googling, and diet orders turn out to exist: OMD in HL7v2, NutritionOrder in FHIR. Joey Chestnut’s chart may require careful unit validation.* ICD-10s for the Fourth (8:43 – 10:42): W39.XXXA, discharge of firework, initial encounter. The one to pursue instead: Y93.G2, grilling and smoking food, which absolutely Pryce nails.* TEFCA’s New Hall Monitor (10:42 – 16:50): The ONC awards a TEFCA auditing contract to an outsider and half the industry misreads it as Sequoia being replaced. The $1.8M contract, the 70-hospital letter, and Brad asking why thirteen QHINs exist if nobody polices their own network.* Alliance Global Tech, Reviewed (16:50 – 22:31): Who won, the TEFCA support page they posted and pulled, and the promise of AI-assisted fraud detection. A moment of silence for AGT’s old website. Impartiality costs expertise, but at least someone is taking a shot on goal.* Information Blocking: Who Gets Enforced First? (22:31 – 31:52): Will enforcement land by end of year? Brendan predicts end of summer with Epic as the politically satisfying target, though the egregious blocking lives down market. Plus whether PointClickCare’s preliminary injunction counts as a proven case (it doesn’t).* The Homer Defense (31:52 – 35:03): Why Epic is the most accused and least guilty information blocker, per aggregate client experience with the Manner Exception. Pryce invokes Hanlon’s Razor. Nobody on this call is being paid by Epic under the table, allegedly.* ...
    Show More Show Less
    41 mins
  • The Information Exchange: What Is Treatment?

    The Information Exchange: What Is Treatment?
    Jun 9 2026
    Should The Information Exchange be renamed Interoperability Office Hours? Last episode we graded TEFCA. This time we’re reviewing homework of our good friends Quinn Emmanuel and Cravath in Particle v. Epic and answering some of the meatiest health information exchange questions of our time.After Judge Buchwald let some claims survive Epic’s motion to dismiss last fall, she did something unusual: rather than open the floodgates to full discovery, she carved out a limited Phase I focused entirely on market definition. But when time was up at the end of May and that didn’t really solve the problem, she doubled down and handed both Particle and Epic a take-home exam.So Pryce, Brad, and I sat down to read each student’s answers:* What is a payer platform, and is there even a market for one (that just includes Particle and Epic)? * What separates a payer from a payvider from a provider, and does anyone actually like the word “payvider”? * When do operations and treatment converge, and why does the pricing gap between the two distort everything around it? We work through all ten questions, the redactions hiding the spicy parts, and what we think Buchwald does next.Fair warning: none of us are lawyers and none of this should be construed as legal advice. However, there’s a sustained rant about arbitrage, and at least one antitrust doctrine gets renamed the “Pryce Ancona break-things” test. Let’s dig in.Relevant Articles* The Take-Home Exam: Summarizing the assignment from Judge Buchwald to Particle and Epic a few weeks ago.* The Doggy-Bag Era of Content: On LLM verbosity and the need for brevity in this era* A River Runs Through It: * Particle v. Epic: The Grandaddy Lawsuit Returns: The first post after Phase I concluded, looking ahead at what’s to come* Older related content* Epic v. Particle: The original summary of Epic and Particle’s Carequality dispute* Epic v. Particle 2: The Problem of Secondary Use: A followup to the above that focused on secondary use and its role in the conflict* The Particle v Epic Casebook: A summary of the case proceedings in October* Amber, Stenotypes, and Antitrust: Epic losing its motion to stay discovery in CureIS, which we were sure Epic was jealous ofChapters* Intro and the Take-Home Exam (0:00 – 4:49): The crew swaps the usual format for a graded exam. Background on Particle v. Epic since September 2024, the surviving antitrust and tortious interference claims, and why Buchwald, skeptical of the alleged market, wants five pages from each side in plain English.* Q1: What Is a Payer Platform? (4:49 – 11:39): Whether Epic Payer Platform and Particle’s product are substitutes in a single market. Pryce’s CDA-to-chart-summary walkthrough, payers paying out the wazoo for treatment-rail data, and the hammer-versus-mallet question of whether a product market exists at all.* Q2: Payer, Payvider, Provider (11:39 – 16:31): Provider is the easy one, payer is the financial risk bearer, and payvider is the term nobody will commit to under oath. Epic disowns the word, the Apple hardware-or-software analogy, and the two-instances-of-Epic compliance boundary.* Q3–Q5: Customer Mix and Active Role (16:31 – 21:24): Particle claims 100% VBC payers and payviders; Epic backdates 23 payer customers plus provider users as a wrinkle. Q4 discovery is a wash, and Q5 on whether a pure payer takes an active role in member health is really question two in disguise.* Treatment, Operations, and the Arbitrage Rant (21:24 – 29:38): The trench-coat problem with payvider, the HIPAA operations definition and HEDIS, and Pryce’s river separating treatment from operations. Brendan’s side quest on pricing treatment exchange at zero while operations pays market rate, and the incentive to abuse the networks.* Q7–Q8: Same Customers, Same Products? (29:38 – 33:44): Whether EPP and Signal serve different customers in different ways. Particle says any differences are implementation detail; Epic says Signal runs one-way over Carequality for treatment while EPP can’t even reach Oracle or Athena. Barrier to entry and whether explaining it this simply undercuts the two-player market.* Q9–Q10: Purpose of Use and the Break-Things Test (33:44 – 37:18): Whether HIPAA purpose of use defines a product market. The Pryce Ancona break-things test on reasonable interchangeability, Epic turning Particle’s Innovaccer argument back on EPP, and the extra-credit treatment question buried under redactions.* Grading the Exam (37:18 – 40:46): Buchwald as philosopher of treatment and operations. Brad finds Epic’s market definition more compelling, Pryce thinks they’re splitting hairs, and Brendan predicts summary judgment against the antitrust claim with the tortious interference count surviving to narrower discovery.* Spurs, Knicks, and Sign-Off (40:46 – End): Playoff trash talk and a closing nod to the underdog in both the court case and the NBA.TranscriptWe ran the transcript ...
    Show More Show Less
    41 mins
  • The Information Exchange: The TEFCA Report Card

    The Information Exchange: The TEFCA Report Card
    May 26 2026
    We are back, but we’re trying something a bit different this time. Given a little Memorial Day lead-up lull afflicting the industry, we decided to give a primer and run-down on the successes and failures of America’s only statutorily blessed nationwide health data exchange: TEFCA two years in, with what's actually working, what isn't, and what the rails really do at this point. Lot of fun this not-a-pod:* The first iteration of our new “Pryce Transparency” segment* Brad as a Trusted Exchange Guinea Pig* Five generations of patient access policy and technology in five minutes* Where Epic stands alone on a FHIR flow that's now an exhibit in active antitrust litigation.* The authentication vs. authorization debate that's becoming the most consequential architectural question in patient access.* Diagnostic imaging’s role in all this (and interop broadly)And of course, what we’re putting on our Memorial Day burgers. Hiring NoticeHTD is hiring! We are looking to bring on Associates to our Interoperability Practice.If you have experience with EHRs, interoperability, and/or consulting and want to:* Work on the deepest, darkest arts of integration and health information exchange* Help the full range from startups to the largest tech companies in the country understand and play in the interoperability landscape* Help EHRs become their better selves (both via collaboration and pressure)* Learn and use regulation deeply as a strategic lever to enable the businesses we work with* Collaborate with a scaled development team across multiple geographies (US, Poland, Argentina)Then respond to this email with your resume and the one big interoperability problem in America you’d solve if you were a policy maker.Relevant Articles* HTI-5: When the Scorpion Learns to Swim: We briefly discuss how HTI-5 is proposing to remove the main “incentive” to join TEFCA, the TEFCA Manner Exception.* Individual Access Services Open Forum: An oldie but goodie primer on how Individual Access Services works and the history behind it.* The Rise of Consumer Health On-Ramps: Detail about the “Big 4” consumer health and patient access on-ramps* Epic’s IAS Implementation: A rant from a year ago about frustrations with Epic’s Individual Access Services implementation* JG Wentworth: Pryce’s mention was like a sleeper activation codeword for me. Real nostalgia rush.* Authorization Tradeoffs: A chart I made when discussing the tradeoffs of different authorization architectures* SMART Imaging Access: Josh Mandel’s reference implementation for patient access to diagnostic images that we talk about* Much Ado about Diagnostic Images: Discussion of the ONC’s RFI on Diagnostic Imaging and a detailed overview of the space* AADJ v. Epic: The Motion to Dismiss: The antitrust case against Epic related to TEFCA IASChapters* Intro and HTD Hiring PSA (0:00 – 0:44): Brendan, Pryce, and Brad pitch HTD’s interoperability associate roles across EHR integration, HIE, payers, clearinghouses, and information blocking strategy.* Pryce Transparency (0:44 – 3:19): A foundational walkthrough of the Trusted Exchange Framework, QHINs as the Verizon and AT&T of federated clinical data, and the difference between treatment queries and Individual Access Services.* Measuring TEFCA Against Itself (3:19 – 8:06): Adoption looks lukewarm next to Carequality on document volume, but two years ago IAS was zero. Pryce’s broken query to his Athena PCP illustrates the fingerprinting problem when something fails and no one can tell whose fault it is.* Five Generations of Patient Access (8:06 – 15:35): From HIPAA right of access through View Download Transmit, scrapers, Cures Act G10 APIs, and now IAS. Each generation solved the prior bottleneck and surfaced the next. Portalitis, Kristen Valdez’s term, and why IAS still falls back to G10 like Apple Pay falls back to cash.* Diagnostic Imaging and the Limits of TEFCA (15:35 – 21:31): Brad’s CD-to-NYU story opens the question of whether new data types ride TEFCA or get their own networks. PACS unregulated, files enormous, 30 competing standards, proprietary vendor incentives. The Dutch precedent with XDS-I and TWIIN shows it can be done, and there are real reasons clinicians want pixels not just reports.* Authentication vs. Authorization (21:31 – 27:39): Pryce walks through how IAS jams identity proofing and data-release consent on rails not designed for the distinction. Epic alone runs the FHIR redirect flow, every other QHIN hands back the treatment CDA with an IAS header, and the antitrust litigation against Epic now treats that architectural choice as an exhibit.* The HIPAA Liability Math (27:39 – 30:37): Why Cleveland Clinic’s general counsel sees only downside without OIG safe harbor. The CMS Health Tech Ecosystem is pushing authentication out anyway, leaving authorization as the more interesting question, including what hospital-side authorization could have unlocked for proxy and ...
    Show More Show Less
    34 mins
adbl_web_anon_alc_button_suppression_t1
No reviews yet