My name is Leslie Manookian, I am the president of Health Freedom Defense Fund (HFDF). I am writing to express our concerns as they relate to the request for information from HHS surrounding the "Health Technology Ecosystem" and what impact this will have on the liberties and freedoms of all Americans. In my personal capacity, during the recently ended Idaho legislative session, I drafted and helped to pass the IDAHO MEDICAL FREEDOM ACT which bans nearly all mandates for the state of Idaho. I did this because I am deeply passionate about civil liberties especially surrounding issues of health.
DIGITAL ID
HHS has put out a request for information at the following link:
https://www.federalregister.gov/documents/2025/05/16/2025-08701/request-for-information-health-technology-ecosystem
Under 3b & d in the Digital Identity section, HHS poses the following question, "Regarding digital identity credentials ... What impact would mandatory credentials have on a nationwide provider directory?" HFDF and I are resolute in our conviction that digital identity must never be a requirement to access healthcare for any American citizen. The entire program should be an opt-in program barring mandates of any kind. However, should the system come to pass, then HHS must provide a valid mechanism to opt-out of such a digital ID requirement without impacting the type or quality of healthcare available to every individual.
BIOMETRICS
Implicit in the questions HHS raises surrounding digital identity is what biometric data requirements will be implemented. Again, HFDF stands staunchly opposed to any biometric data requirement for any American to access healthcare and should such requirements come to pass, there MUST be permanent valid op-outs without impacting the type or quality of healthcare provided.
WEARABLES
When it comes to wearable technology every American should have the right to decide whether to utilize such technology or not. The IDAHO MEDICAL FREEDOM ACT explicitly prohibits any private or state actor from requiring a medical interventions or requirements including devices and wearables in order to lead a normal life. It is a little-known fact that in 2018 the state of West Virginia attempted to require all teachers to wear Fitbits to access medical insurance. The teachers rose up in what became a historic strike and this requirement was abolished. The attempt by authorities to impose such a requirement illustrates that some stakeholders take no issue with mandating wearable technology. This morally repugnant stance implies that human beings are nothing more than livestock to be tagged and must never be tolerated in America, a nation that values human dignity and the value of every individual. A West Virginian teacher discusses this issue at the following link: https://www.youtube.com/watch?v=pa9MVP5aMdQ
The "right to be forgotten"
With the rise of AI and data being viewed as "the new oil," some European nations have placed value on a concept known as "the right to be forgotten." If a patient receives medical care from a doctor or provider who is using AI tools, the patient has the right to determine whether their information is saved in a database or deleted permanently.
Thank you for your time and consideration.
Direct link to the public comment.
