A high-leverage metric CMS could adopt for its Horizon 3 initiatives is lead time to learn: the elapsed time from a state deciding to try something, to a running experiment, to proven or disproven outcomes, to a decision about what to do next. Today that cycle is measured in years. APD approval, procurement, contracting, and certification each add months before learning is achieved. By the time we gain actual experience with a proposed solution, the policy context has changed, the people have changed, and the learning is stale.
As decisions about standards for Horizon 3 processes are being made, we recommend considering whether the proposal will shorten or lengthen the time it takes a state to learn. Standards that shorten it (shared test environments, reusable reference implementations, pre-approved experiment pathways) are worth building. Standards that lengthen it (complex enterprise architecture models, new compliance checkpoints, additional documentation gates) will make the underlying problem worse regardless of their technical merit. We recommend CMS measure and publish lead time to learn across states and design APD and certification touchpoints as enablers with highly-responsive service-level commitments.
Federal rules are not the only driver of lead time. State governance, procurement practices, and team structures add delay too, which is why the measurement must cover the whole cycle, not just the federal touchpoints. Measured end to end and published by segment, the metric shows every owner of delay their share. CMS can then help states shorten their own segments without new mandates: recognize lead-time diagnostics and process improvement as APD-eligible activities, convene peer exchanges where states with shorter cycles share how they got there, and offer technical assistance to states that request it. This support must stay opt-in, or the remedy becomes one more gate that lengthens the cycle it exists to shorten.