Open Challenge

The Cures Act Makes QIS Unstoppable

60+ companies pledged to transform healthcare data. But the law already guarantees patients can access their own records—and share them with any network they choose. The question isn't if QIS will happen. It's whether you'll lead or be bypassed.

By Christopher Thomas Trevethan · January 7, 2026

On July 30, 2025, over 60 of the most powerful companies in healthcare and technology gathered at the White House. They signed a pledge. They made commitments. They promised to transform how health data flows—and more importantly, how it gets used to save lives.

This is an open letter to every company that signed that pledge.

I'm not here to criticize what you committed to. I'm here to show you a technology that delivers on it—better than traditional interoperability ever could. And I'm here to pose a question you'll need to answer: once you know this technology exists, what do you do next?

The Pledge You Signed

🏛️
"Make Health Tech Great Again"
The White House • July 30, 2025

President Trump, HHS Secretary Robert F. Kennedy Jr., and CMS Administrator Dr. Mehmet Oz announced the CMS Health Tech Ecosystem Initiative—a voluntary framework to "easily and seamlessly share information between patients and providers" and expand digital health tools "so that patients have the information and resources they need to make better health decisions."

60+ companies pledged to deliver results by Q1 2026.

The companies who signed include the biggest names in technology and healthcare:

Amazon
Apple
Google
Microsoft
OpenAI
Anthropic
Oracle
Epic
UnitedHealth Group
Humana
Aetna
Elevance Health
Cleveland Clinic
CVS Health
Intermountain
athenahealth
Samsung
Zocdoc

And many more. The full list includes 21 networks pledging to become "CMS Aligned Networks," 11 health systems committing to support patient use, and 7 EHR vendors agreeing to "kill the clipboard."

"For decades, bureaucrats and entrenched interests buried health data and blocked patients from taking control of their health. That ends today."
— HHS Secretary Robert F. Kennedy Jr., July 30, 2025
"For too long, patients in this country have been burdened with a healthcare system that has not kept pace with the disruptive innovations that have transformed nearly every other sector of our economy."
— CMS Administrator Dr. Mehmet Oz, July 30, 2025

These are powerful words. And the pledge commits to powerful goals: seamless data exchange, patient empowerment, real results by Q1 2026.

But here's the paradox: traditional interoperability—moving data between systems—isn't the same as maximizing the USE of that data to save lives.

The Law: What "Use" Actually Means

The pledge builds on existing law—specifically, the 21st Century Cures Act, signed in December 2016 with overwhelming bipartisan support. The Cures Act prohibits "information blocking" and directs the healthcare industry to support the access, exchange, and use of electronic health information.

21st Century Cures Act — Information Blocking Definition (45 CFR 171.103)

Information blocking is defined as a practice that is likely to "interfere with, prevent, or materially discourage access, exchange, or USE of electronic health information."

Penalties: Up to $1 million per violation for health IT developers, health information networks, and health information exchanges. Healthcare providers face "disincentives" through Medicare programs, effective July 31, 2024.

Most discussions of the Cures Act focus on access and exchange—moving data from point A to point B. But the law explicitly protects something more: the USE of health information.

What does "use" mean?

It means taking health information and doing something valuable with it. Synthesizing insights. Making better decisions. Improving outcomes. The law doesn't just protect data pipes—it protects the intelligence that flows through them.

Here's what makes this law so powerful for QIS: the Cures Act guarantees patients access to their own health data. Every patient portal, every EHR system—by law, they must provide patients with their complete health information. No institution can legally refuse.

Which means no one can tell a dying patient they can't share their own data with a QIS network. No one can stop a cancer patient from exporting their records and plugging into a swarm that extracts the relevant features, creates a semantic fingerprint, and synthesizes outcome packets from similar cases worldwide. The institution doesn't have to participate. The patient can route around them entirely.

The organizations that signed the White House pledge have a choice: participate in QIS—bring their R&D expertise to curate the sharpest patterns, define the best similarity metrics, build the most effective domain templates—or watch their patients plug into networks built by others. The question isn't whether QIS will happen. The law guarantees patients can access their data—and from there, life-saving insight will flow. The question is whether you'll help shape how it's used.

And that raises an uncomfortable question.

The Question You'll Need to Answer

If a technology exists that enables dramatically better use of health information—quadratic intelligence scaling instead of linear data transfer—and you choose not to implement it while patients suffer...

Are you "materially discouraging the USE of electronic health information"?

I'm not a lawyer. I can't tell you whether refusing to implement superior technology violates the letter of the Cures Act. But I can tell you this:

The spirit of the law is to maximize patient benefit from health information. The purpose of your pledge is to improve outcomes. And a technology exists—right now—that does both in ways traditional interoperability cannot.

That technology is the Quadratic Intelligence Swarm (QIS) Protocol.

What QIS Actually Does

Traditional interoperability moves data between systems. QIS creates intelligence from distributed data—without moving the data at all.

Aspect Traditional Interoperability QIS Protocol
What flows Raw data, records, documents Outcome packets—semantic patterns that are the insight itself
Privacy model Data must be shared or aggregated Raw data never leaves the source
Scaling Linear (N data sources = N insights) Quadratic (N agents = N(N-1)/2 synthesis opportunities)
Timing Batch transfers, periodic updates Real-time pattern matching
Architecture Centralized or federated Decentralized (hybrid and centralized variants also supported)
What patients get Access to their own records Outcome packets synthesized from cohorts matched by expert-defined similarity

Here's the core insight: when N agents can route by semantic similarity and synthesize patterns with matched peers, intelligence scales as N(N-1)/2—quadratic, not linear.

For 10,000 patients, that's not 10,000 isolated records. That's nearly 50 million unique synthesis opportunities. Each patient gets real-time access to outcomes from similar patients worldwide—what treatments worked, what didn't, what to watch for—without anyone's raw data ever leaving their control.

Every component of QIS is proven technology deployed at massive scale: similarity-based routing (vector databases, DHTs, recommendation engines), semantic embeddings (Google Search, ChatGPT), consensus and synthesis rules (how insights are tabulated, votes weighted, outcomes aggregated). QIS doesn't require new inventions or rely on untested theory. Every single component already exists and is battle-tested at planetary scale. QIS simply connects these proven pieces for a purpose no one thought to connect them for before.

How QIS Fulfills Your Pledge

Let me be specific about how QIS delivers on the commitments you made:

"Eliminate walled gardens"

Traditional approach: Build pipes to move data between gardens.
QIS approach: Gardens share outcome packets without sharing data. Walls stay up for privacy. Intelligence flows anyway.

"Patient access to health information"

Traditional approach: Patients can view their own records.
QIS approach: Patients access outcome packets synthesized from everyone's anonymized patterns—not just their own records.

"No centralized database"

Traditional approach: Federated data stores with central coordination.
QIS approach: Fully decentralized. No coordinator. Patterns find each other through semantic routing.

"Patients in control"

Traditional approach: Consent management for data sharing.
QIS approach: Patients control what outcome packets are published. Raw data never moves. Control is absolute.

"Kill the clipboard"

Traditional approach: Digital intake forms.
QIS approach: Intelligent pattern matching from first contact. The system already knows what's relevant before you fill anything out.

QIS doesn't replace your pledge commitments. It fulfills them at a level you may not have imagined possible.

The Five Questions

I'm not asking you to take my word for any of this. I'm asking you to answer five questions:

Question 1: Technical Feasibility
Have you evaluated QIS for technical feasibility?
You committed to FHIR-based interoperability. QIS works with FHIR and every other standard—it's protocol-agnostic. The components are all proven. What's your assessment?
Question 2: Patient Benefit
Have you assessed how QIS could improve outcomes for your patients, members, or users?
You pledged to improve health outcomes through better data use. QIS enables quadratic intelligence scaling. Have you quantified what that could mean for the people you serve?
Question 3: Implementation Timeline
What is your timeline for evaluating QIS?
You committed to delivering results by Q1 2026. QIS can be implemented on existing infrastructure. When will you make a decision?
Question 4: Legal Assessment
How does refusing to implement known-superior technology align with your Cures Act obligations?
The law prohibits practices that "materially discourage the USE of electronic health information." If QIS enables superior use, what's your legal position?
Question 5: Moral Responsibility
What is your response to patients who could benefit from this technology?
You stood at the White House and pledged to help patients. QIS could save lives through real-time insight sharing. What do you say to those patients?

The Stakes

If You Do Nothing

  • Patients continue receiving siloed care based on isolated records
  • Treatment decisions lack real-time insight from similar cases
  • Quadratic intelligence potential remains unrealized
  • A documented record exists that you were informed
  • Someone else builds this—and you explain why you didn't

If You Act

  • Patients gain access to outcome packets from every similar case—similarity defined by the best experts each network can hire
  • Treatment optimization happens in real-time, not multi-year trials
  • Your pledge commitments are fulfilled at a level beyond expectation
  • You lead the transformation you promised
  • Lives are saved that would otherwise be lost

The Context: This Isn't Theoretical

I'm not approaching this from a position of naivety about how the healthcare industry works. I've watched the gatekeeping firsthand:

September 2024
Particle Health v. Epic: A startup filed an antitrust lawsuit against Epic, alleging the EHR giant used its market power to block patient data access. In September 2025, a federal judge allowed core monopolization claims to proceed—the first time Epic has faced antitrust allegations that got this far.
September 2025
HHS Crackdown: The Trump administration announced renewed enforcement of information blocking rules. "Information blocking was not a priority under the Biden Administration. That changed under President Trump and Secretary Kennedy."
July 31, 2024
Provider Disincentives: Penalties for healthcare providers who commit information blocking became effective—including potential exclusion from Medicare quality programs.

The regulatory environment is shifting. The legal landscape is evolving. And the expectations set by your own pledge create a new baseline for what "good faith" looks like.

I'm offering you a path forward that exceeds those expectations.

The Invitation

The Door Is Open

I'm not threatening legal action. I'm not demanding anything. I'm extending an invitation.

QIS is available for licensing. The protocol specification is public. The math is documented. The implementation pathway is clear.

You committed to transforming healthcare data. I built a technology that delivers on that commitment. The question isn't whether this works—the components are proven at scale. The question is whether you'll evaluate it seriously.

The ball is in your court. I'm here when you're ready to talk.

My father died because a pattern existed somewhere that could have saved him, but data silos kept it hidden. My brother is permanently damaged because the right insight didn't reach the right doctor in time.

These weren't failures of technology. They were failures of architecture. Failures of imagination. Failures to see that the same data—organized differently—could have changed everything.

You signed a pledge to fix this. I built a technology that actually does. The rest is up to you.

Ready to Evaluate QIS?

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