MITA has been the definitional frame for MES modernization for two decades. In that time it has produced enormous quantities of maturity assessments, capability matrices, and architecture documentation, and approximately zero transformed Medicaid enterprises. The framework describes; it does not deliver. Worse, it consumes the scarce attention of exactly the people who could deliver, redirecting them into documentation exercises whose primary consumer is the compliance process itself.
This is not a distant critique. I participate in MITA workgroups and discussions. For years, I have asked vendors and state leaders a simple question: what do you value about MITA? I have never once received an outcome-oriented answer. Vendors value it as dependable, low-risk revenue: structured work that must be done, regardless of whether it changes anything. State leaders value it as a funding pathway: boxes checked, compliance satisfied, dollars unlocked. Some have gone further, describing the appeal of paying a vendor to complete MITA work precisely so their own teams do not have to think about it. Every one of these answers describes MITA’s value as the avoidance of work that matters. None connects it to a resident served, a caseworker’s day improved, or a dollar better spent. Two decades in, that silence is the evaluation.
The RFI asks which standards are underutilized. The honest answer is that the industry standards that matter (FHIR, X12, NIST) are underutilized not because states lack a framework that mentions them but because very little in the delivery environment rewards using them. A standards lifecycle that prevents technical debt accumulation (question SE-8) is one where standards are small, running, testable, and retired when the running evidence stops supporting them. Frameworks maintained as documents accumulate debt by design.
Define the Horizon 3 program around outcomes and working software, reference industry standards where they serve, and let MITA rest.