Evidence Vault

The Regulatory Catalyst: The Administration for A Healthy America (AHA)In 2025, the federal government initiated a dramatic restructuring of its health apparatus, consolidating 28 disparate divisions into 15 streamlined units. At the center of this reorganization is the Administration for a Healthy America (AHA). This new agency absorbs functions from the CDC, HRSA, and SAMHSA with a singular, high-stakes objective: reversing the chronic disease epidemic by addressing its "root causes".Under the leadership of Secretary Robert F. Kennedy Jr. and Commissioner Marty Makary, the AHA is moving away from the "medical dogma" of the last half-century. The agency’s focus has shifted toward metabolic health, environmental exposures, and nutrition. For the first time, federal policy is not just aimed at "treating" conditions like Type 2 diabetes or hypertension, but at providing the regulatory and financial incentives necessary to "reverse" them.The Evidence Gap: The Failure of Administrative ProxiesThis shift creates a fundamental problem for the current healthcare infrastructure. For decades, the industry has relied on Administrative Proxies — billing codes and claims data — to measure success. However, a billing code for "diabetes management" only proves that a service was rendered; it does not prove that the disease was reversed or that the "root cause" was addressed.As the AHA and CMS move toward Value-Based Contracting that rewards actual disease reversal, the lack of clinical depth in legacy systems has become a "Measurement-toManagement Gap. "To secure reimbursement in this new era, providers must move beyond "Data Exhaust" and provide Verified Clinical Veracity.The Circle Solution: Engineering Outcomes at The NodeThe Circles platform provides the Regulatory-Grade Governance required to meet the AHA’s mandate. By defining clinical protocols before the patient encounter, Circles ensure that every data point captured is a reflection of actual clinical change rather than administrative convenience.Standardized Longitudinal Scores (SLS): Circles capture objective markers — such as metabolic panels, functional movement scores, and patient-reported outcomes — over time. This allows a clinical node to prove "reversal" with an Audit-Ready "Ground Truth" that federal reviewers can verify.Outcome Engineering: By moving the focus from "sick care" to "root-cause reversal, "Circles enable clinicians to track the efficacy of interventions like the new 2026 dietary guidelines. This transforms a standard clinic into a high-veracity research node capable of proving that "food as medicine" actually works.Surgical-Delay Proof: For surgeons and specialists, this data provides the "Insurable Integrity" needed to justify procedures in an environment where payers are increasingly focused on conservative, root-cause alternatives.Strategic Outcome: Reclassifying The EnterpriseThe AHA reorganization has turned "outcome data" into the most valuable currency in healthcare. Clinical organizations that continue to rely on fragmented EHR notes will face increasing downward pressure on reimbursement and valuation.In contrast, organizations that utilize Circles to provide Verified Clinical Veracity are reclassified as Tech-Enabled Assets. This shift is the primary driver of Multiple Expansion, moving an entity from a 6–8x service multiple to a 12–15x asset multiple. The valuation of the MSO is no longer tied to the number of patients seen, but to the Insurable Integrity of the reversals it can prove.

The Regulatory Catalyst: The 60-day ReviewIn 2025, FDA Commissioner Marty Makary introduced the Commissioner’s National Priority Voucher (CNPV), a pilot program that reduces the standard 10–12 month review clock to a mere 30–60 days. Designed to fast-track treatments that align with "U.S. National Interests"— such as onshoring manufacturing, increasing affordability, or tackling the chronic disease crisis — the NPV replaces the traditional, sequential review process with a multidisciplinary, "tumor board style" evaluation.By January 2026, the first wave of approvals has proven that the "red tape" of the past century can be bypassed. However, this acceleration has created a "Scientific Reputational Risk". Career scientists and outside experts have expressed concerns that ultracompressed windows may sacrifice the rigor required to identify long-term safety signals. For the manufacturer, the prize of early market entry now comes with a significant tail of legal and clinical liability.The Evidence Gap: The "Speed-to-Payer" BarrierThe true bottleneck is no longer the FDA; it is the payer. Public and private insurers have historically been skeptical of products that bypass traditional evaluation pathways, often delaying coverage until "sufficient" real-world safety and efficacy data emerges.This creates a "Measurement-to-Management Gap. " A drug or device may be legally approved in 60 days, but if the manufacturer cannot provide Verified Clinical Veracity of its performance in the real world, it will languish in "reimbursement limbo". Legacy "Data Exhaust"— static snapshots from billing and claims — is too slow and too imprecise to satisfy insurers who are now assessing the adequacy of the FDA’s truncated review.The Circle Solution: Insurable Risk ModelingThe Circles platform provides the infrastructure to bridge this gap through Insurable Risk Modeling. By establishing Regulatory-Grade Governance at the clinical node, Circles allow manufacturers and providers to monitor performance in real-time, effectively extending the "clinical trial" into the "real-world" without loss of data integrity.Verified Clinical Veracity: Circles capture Standardized Longitudinal Scores directly from the patient and provider, creating an Audit-Ready "Ground Truth" that can be shared with payers to accelerate coverage decisions.Safety-in-Motion: Because Circles operate with pre-structured Observational Protocols (OPs), it can identify safety or efficacy signals months faster than traditional post-market surveillance. This "Safety-in-Motion" is the only viable defense against the liability risks inherent in accelerated approvals.Surgical-Delay Proof: For clinical organizations, this data architecture ensures that ValueBased Care transitions are not stalled by insurer skepticism. You aren't just performing a procedure; you are generating the Insurable Integrity that justifies the payment.Strategic Outcome: Capturing The "Integrity Premium"In a 60-day review environment, the "Insurable Integrity Premium" becomes the primary driver of enterprise value. Organizations that rely on administrative proxies will be seen as high-risk liabilities. Organizations that utilize Circles to provide transparent, verifiable outcomes will be viewed as Tech-Enabled Assets.For the healthcare executive, this is the path to Multiple Expansion. By owning the veracity of the data, the clinical entity moves from a 6–8x service multiple to a 12–15x asset multiple, fundamentally decoupled from the volatility of the new regulatory speed.

The Regulatory Catalyst: The Rise of ORIVAIn 2025 and early 2026, the National Institutes of Health (NIH) fundamentally reorganized its research priorities by establishing the Office of Research Innovation, Validation, and Application (ORIVA). This office was created with a singular, high-stakes directive: to transition the U.S. biomedical research portfolio away from traditional animal models and toward "human-based research technologies".This is not merely an ethical shift; it is a response to a persistent "translational failure" in medicine. For decades, approximately 90% of drugs that appeared safe and effective in animal trials failed when reached human subjects, often due to fundamental physiological differences that animal models simply cannot replicate. Under Commissioner Marty Makary, the FDA has synchronized with this NIH shift, releasing a "Roadmap to Reducing Animal Testing" that prioritizes New Approach Methodologies (NAMs) — specifically AI-driven computational models and high-veracity Real-World Data (RWD).The Evidence Gap: The "Translational Trap"The "Translation Trap" occurs when researchers rely on animal data that is "internally valid" (consistent within the lab) but "externally invalid" (fails in the human population). As the FDA Modernization Act 2.0 and 3.0 take full effect in 2026, the agency is now authorized to accept human biology-based evidence in place of animal studies for Investigational New Drug (IND) applications.However, this transition creates a new "Measurement-to-Management Gap." Computational models and AI simulations are only as reliable as the data used to train and validate them. Most existing human data is "Data Exhaust" — static snapshots from insurance claims or electronic health records (EHRs) that lack the longitudinal depth and clinical precision required to replace a controlled animal study. To satisfy the new "human-relevant" standard, the industry requires Verified Clinical Veracity captured in real-time.The Circle Solution: Engineering Human OutcomesThe Circles platform provides the infrastructure required to bridge this gap. By utilizing Observational Protocols (OPs), Circles enable clinicians across any specialty — from neurology to metabolic health — to capture a "Human Ground Truth" that is both longitudinal and audit-ready.Longitudinal Precision: Circles do not capture a single point in time; they track Standardized Longitudinal Scores (e.g., functional assessments, patient-reported outcomes, and metabolic markers) over months and years.Regulatory-Grade Governance: Unlike unstructured EHR notes, data within a Circle is governed by predefined clinical guardrails. This ensures the data is "Audit-Ready" for federal agencies that are now scrutinizing human-based evidence as a replacement for preclinical animal models.Validating the "In Silico" World: As the NIH and FDA move toward "in silico" (computersimulated) trials, Circles provide the high-fidelity human outcomes necessary to validate those models, ensuring they reflect actual clinical reality rather than statistical projections.Strategic Outcome: Valuation Via Insurable IntegrityIn the legacy research model, clinical documentation was a sunk cost of the procedure. In the new 2026 regulatory environment, Verified Clinical Veracity is a strategic asset. By generating data that meets the FDA’s "human-relevant" mandate, a clinical organization moves from a low-margin service provider to a Tech-Enabled Asset.The value of the organization is now tied to its Insurable Integrity — the ability to provide a data set that is robust enough to bypass or supplement traditional, expensive research phases. This transition is the primary driver for Multiple Expansion, allowing healthcare entities to capture the "Insurable Integrity Premium" that the current administration is making essential for medical innovation.

The Reality For Providers Of A $4T Healthcare EconomyHealthcare in the U.S. represents a full 18% of the country’s GDP. While there are many players in such a large “market”, none is more critical than hospitals and other provider groups. However, most operate on low, unpredictable margins. Reimbursement rates are under growing pressure, research grants are being slashed, competition is stiffer, and costs are rising. Compliant, Minimal Cost and Burden The Asset and Income Stream Untapped By Most Provider GroupsThe real-world data which arises each day in the context of practice-of-medicine – when properly structured, correlated with outcomes measures, and unambiguously owned – can represent one of the most important financial assets of a hospital system. This has already been recognized by major groups such as Mayo Clinic and Duke Health. Circle Datasets make those opportunities available to any size provider group. The more successful groups have developed income streams beyond medical care fees. A good example is “tech transfer” or “innovation” departments, controlling shared ownership of and monetization of intellectual property developed by the group’s physicians and scientists. The Value of Circle DatasetsCircle Datasets also represent highly monetizable intellectual property for providers. The healthcare data analytics market is valued at $50B, with a 20% annual growth rate. It is based largely on electronic medical, claims, revenue cycle, prescription and similar digital records originating with providers. Yet those providers see little if any of that value. Circle Datasets invert that model by giving provider groups unambiguous ownership of – and value for – their real-world data. The patented technical infrastructure underlying Circle Datasets is designed to meet BAA requirements. They can be generated with minimal clinical burden and cost. Combined with simple, flexible contracting, this allows provider groups to begin with a small pilot, and then scale consistent with pre-defined KPIs.Moreover, Circle Datasets are clinically and statistically relevant for each clinical context, correlated to long-term outcomes measures, and verifiable to primary sources. As such, they are significantly more valuable than typical real-world evidence datasets. Moreover, that value has only increased as a result of the FDA’s December 2025 guidance on real-world evidence.Federated Data Ownership Structure; FHIR-Mapped For provider groups, local control of clinical data is increasingly important. On the other hand, collaboration with other centers of excellence can often open up important clinical, scientific, and financial opportunities. Circle Datasets support both through a federated data architecture approach. Moreover, they are FHIR-mapped, supporting interoperability with other systems.‍

The Regulatory Catalyst: Removing The Identity BarrierIn December 2025, the FDA issued a final guidance that fundamentally changed how it evaluates Real-World Evidence (RWE). For years, the agency largely required "identifiable" patient-level data — specific names or social security numbers — to verify the accuracy of medical studies. Because privacy laws (HIPAA) and security protocols often require data to be de-identified, this created a structural barrier that disqualified vast amounts of highvalue clinical information from being used for drug or device approvals.The new mandate removes this requirement. Commissioner Marty Makary has characterized this as a shift toward "radical transparency," where the agency no longer asks "Who is the patient?" but rather "Is the data true?". The FDA will now accept de-identified datasets, provided the source can prove the information is accurate, reliable, and scientifically sound.The Evidence Gap: Administrative Proxies VS. Ground TruthWhile this "unlocks" massive amounts of data, it also exposes a significant flaw in current healthcare systems. Most medical data today consists of "administrative proxies"— billing codes, insurance claims, and fragmented notes captured for the purpose of payment. These proxies are often inaccurate and lack the clinical depth required for federal audits or highstakes licensing.To take advantage of this new regulatory path, organizations must move toward Regulatory-Grade Governance. This means defining the data architecture and clinical guardrails before the patient encounter begins. By using Circles’ Observational Protocols (OPs), providers create an Audit-Ready "Ground Truth" that makes billing errors or protocol deviations technically impossible.The Economic Model: From Service To AssetThis shift transforms the clinical record. Historically, documentation has been a regulatory burden — a cost center. In the new FDA environment, verified data becomes a high-margin, licensable asset.The Circles platform provides the infrastructure for this transformation across any medical specialty — from oncology to neurology. By capturing Standardized Longitudinal Scores and objective outcomes at the point of care, Circles ensure that every patient encounter generates Verified Clinical Veracity. This data does not just meet the new FDA standard; it exceeds it, providing the Insurable Integrity that allows for faster approvals and lower liability risks.Strategic Outcome: Valuation ExpansionFor Management Services Organizations (MSOs) and healthcare boards, the objective is Multiple Expansion. By transitioning from a "Service Business" focused on volume to a "Tech-Enabled Asset" focused on high-veracity data, organizations can significantly increase their valuation multiples. The value of the enterprise is no longer just in the procedure performed, but in the Insurable Integrity of the evidence created.

The Cult Of MagnitudeIn the mythology of machine learning, scale equals truth. We are told that the more data a model consumes, the more “generalizable” its intelligence becomes. In medicine, this logic has become gospel — aggregating millions of records, billions of data points, all to simulate the judgment of a single good clinician. But the assumption is flawed.Scale amplifies patterns; it does not clarify meaning. When bias, incompleteness, or error arealready present, multiplying them by a million produces not insight but illusion — the statistical equivalent of shouting nonsense louder.The Diminishing Returns Of VolumeEmpirically, performance gains in large models plateau long before ethical or clinicalreliability is reached. Beyond a threshold, each additional terabyte adds noise faster thansignal, correlation faster than causation. More data does not make the world more knowable; it merely makes its distortions more precise.This is why most AI systems trained on aggregated EHR data behave like echo chambers — reproducing the biases of documentation, not the biology of disease. In medicine, volume without veracity is not strength but fragility at scale.The Loss Of ContextEvery datum stripped from its origin loses a layer of meaning. When data is extracted, cleansed, and normalized, it often sheds the metadata — time, setting, instrument, decision rationale — that made it interpretable. The process that was supposed to make the dataset objective instead makes it contextually blind. A radiograph taken at 2 a.m. in an ICU cannot be treated as equivalent to one taken at 2 p.m. in an outpatient clinic.Yet that is exactly what “large-scale learning” does: it homogenizes circumstances until only pixels remain. AI that learns from such data cannot tell the difference between physiology and logistics.The Federation AdvantageFederation restores the context that centralization erases. Instead of collapsing local meaning into a global average, federated architectures like Circle Datasets preserve the individuality of each institution’s data while harmonizing their structure. The model learns across differences without erasing them — a distributed epistemology that treats variability as truth, not noise.In this sense, federation is not just a privacy measure; it is an epistemic correction. It allows medicine to learn the way biology learns: locally adaptive, globally coherent.Quality As The New ScaleTrue “size” in healthcare data will no longer be measured in rows or terabytes, but in verifiable completeness per case.A single patient record, longitudinally documented, consistently coded, and contextually validated, is worth more than ten thousand fragments stripped of meaning. Circle Datasets invert the metric: the depth of record replaces breadth of population.This is not downsizing; it is precision scaling — measuring value by integrity, not accumulation. The next era of model development will reward precision of provenance over abundance of data.The Moral Arithmetic Of ScaleScale without governance creates moral distance. When no one can see the patient behind the data, error becomes acceptable and harm becomes invisible. Federation reintroduces proximity — it makes someone responsible for every data contribution. That proximity converts ethics from abstraction into practice.At smaller, governed scales, clinicians rediscover ownership of meaning; systems rediscover accountability; patients rediscover agency. Scale ceases to be an idol and becomes an instrument.Redefining The “BIG” In Big DataMedicine’s great epistemic correction will not come from bigger models but from smaller errors. Federation and provenance allow data to retain its truth at source, transforming “big data” into trusted data — modular, validated, and explainable. The future of learning health systems depends on this redefinition. The question will shift from “How much do we have?” to “How much of what we have is real?” That is not a retreat from ambition. It is the only way to make scale finally intelligent.