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Turquoise Health submits public comment on the health technology ecosystem request for information

The RFI includes specific questions focused on price transparency and binding cost estimates for pre-defined periods

June 17, 2025
Turquoise Health submits public comment on the health technology ecosystem request for information

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Authors

Chris Severn
Chris Severn
CEO, Co-Founder
Carol Skenes
Carol Skenes
Chief of Staff

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Earlier this month, Turquoise Health submitted a public comment in response to CMS-0042-NC, a Request for Information (RFI) focused on the health technology ecosystem.

We focused our feedback on two specific sections of the RFI:

  • PC-12; regarding binding cost estimates for pre-defined periods as valuable operational health data use cases for patients and caregivers
  • TD-19; regarding price transparency implementation

Turquoise is in full support of CMS’ commitment to using price transparency data and innovative frameworks to create binding upfront cost estimates. The Turquoise site has thousands of patients engaging with our data, and each of those site visits points to the need for clarity and transparency in understanding the cost of care.

Our full comment can be summarized as follows:

  • We emphasize the importance of enforcement dates for AEOBs and GFEs as the primary mechanism for for binding cost estimates
  • We offer an open-source framework as an innovative solution for creating service packages to fulfill the No Surprises Act requirements and allow patients to understand their cost of care up front
  • We summarize the highest-impact workflow improvements and benefits from price transparency
  • We offer practical paths to motivate solution development

Read the full comment here.

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