By the EHR Association AI Task Force

On January 10, 2025, the Assistant Secretary of Technology Policy (ASTP) released the U.S. Department of Health and Human Services (HHS) Strategic Plan for the Use of Artificial Intelligence in Health, Human Services, and Public Health.

In the press release announcing its release, HHS described the Strategic Plan as establishing both the strategic framework and operational roadmap for responsibly leveraging emerging technologies to enhance HHS’s core mission while maintaining its commitment to safety, effectiveness, equity, and access. It also outlines the ways HHS will deliver on its goal of being a global leader in innovating and adopting responsible AI that achieves unparalleled advances in the health and well-being of all Americans.

We need to ensure that Americans are safeguarded from risks. Deployment and adoption of AI should benefit the American people, and we must hold stakeholders across the ecosystem accountable to achieve this goal.

“At HHS, we are optimistic about the transformational potential of AI,” said Deputy Secretary Andrea Palm. “These technologies hold unparalleled ability to drive innovation through accelerating scientific breakthroughs, improving medical product safety and effectiveness, improving health outcomes through care delivery, increasing access to human services, and optimizing public health. However, our optimism is tempered with a deep sense of responsibility. We need to ensure that Americans are safeguarded from risks. Deployment and adoption of AI should benefit the American people, and we must hold stakeholders across the ecosystem accountable to achieve this goal.”

Key Plan Points

The Strategic Plan outlines how HHS will mobilize an approach to improve the quality, safety, efficiency, accessibility, equitability, and outcomes in health and human services through the innovative, safe, and responsible use of AI by focusing on four key goals:

1. Catalyze health AI innovation and adoption to unlock new ways to use AI to improve people’s lives;
2. Promote trustworthy AI development and ethical and responsible use to avoid potential harm;
3. Democratize AI technologies and resources to promote equitable access for all; and
4. Cultivate AI-empowered workforces and organizational cultures to allow staff to make the best use of AI.

HHS says it will adopt a dynamic approach to AI to stay ahead of its rapid evolution while addressing emerging challenges that include Plan updates, continuous risk assessment, stakeholder engagement, and the implementation of robust safeguards that ensure ethical and equitable AI use.

The EHR Association Stance

The EHR Association AI Task Force shares the following thoughts on areas of the Strategic Plan that are of specific interest to the Association’s member companies and the providers who utilize their EHR and other health IT.

We are pleased to see plans to leverage USCDI, USCDI+, HL7, FHIR, and other data standards, along with a focus on TEFCA as a potential transport for information that may be utilized in AI workflows for training or insights. Leveraging the standardized data that already exists in many EHRs will accelerate development of solutions speaking a ‘common language’, as well as the opportunity to benefit from novel AI technologies in the future.

“We are pleased to see plans to leverage USCDI, USCDI+, HL7, FHIR, and other data standards, along with a focus on TEFCA as a potential transport for information that may be utilized in AI workflows for training or insights. Leveraging the standardized data that already exists in many EHRs will accelerate development of solutions speaking a ‘common language’, as well as the opportunity to benefit from novel AI technologies in the future. We are also encouraged to see the ‘human in the loop’ concept throughout the Strategic Plan as a strategy to mitigate risk, particularly at this state of AI maturity,” says Tina Joros (Veradigm), Chair, EHR Association AI Task Force.

When it comes to the expanded scope of HHS responsibilities to appropriately guide safe AI development as outlined in the Plan, Joros notes that “HHS acknowledges that healthcare stakeholders will increasingly use AI technologies and tools that fall outside the scope of FDA regulation or ASTP/ONC authority, including the HTI-1 regulation.”

She adds, “We support conversations about where additional authority may be necessary for HHS to offer meaningful incentives to create uniform standards across the entirety of the healthcare AI ecosystem and not just Certified Health IT. To the extent these incentives also extend to providers using Certified Health IT, they have the potential to spur adoption of AI and build a trusted, transparent system that will help mitigate the risk and cost of adopting new technologies.”

The recognition of the opportunity that exists through artificial intelligence in administrative workflows is a great callout. Innovation in this space can safely improve burnout, as well as the overall cost of healthcare delivery, and thus should be prioritized by policymakers and software developers.

The Association also commends HHS for recognizing the clinical risk inherent in the use of AI in healthcare. AI Task Force Vice Chair Stephen Speicher, MD (Flatiron Health), states: “It is important to take a risk-based approach to developing and deploying AI directly into the healthcare ecosystem. In the AI Strategic Plan, HHS appropriately recognizes the risks that can stem from using AI in high-risk clinical workflows, including diagnosis and treatment, as well as apprehensions about the topic felt by some providers and patients. The recognition of the opportunity that exists through artificial intelligence in administrative workflows is a great callout. Innovation in this space can safely improve burnout, as well as the overall cost of healthcare delivery, and thus should be prioritized by policymakers and software developers.”

Dr. Speicher also acknowledges the potential for AI to widen the technological divide that exists in the U.S. healthcare system and the importance of prioritizing equitable access to AI innovation across the ecosystem.

“A technological divide exists in healthcare in this country, with large high-volume centers in major cities frequently outpacing smaller centers caring for underserved communities,” he says. “We must ensure the deployment of AI technology in healthcare is accessible to small private practices as well as large academic medical centers and health systems to ensure that health equity improves over time in all care settings. Failing to prioritize this, as HHS calls out, risks a further divide in the quality of care available to individuals based on race, ethnicity, zip code, and other demographic factors.”