Healthcare technology is set to undergo a monumental transformation, moving from a focus on EHR functionality to a focus on API exchange. At the heart of this evolution lies interoperability, the ability to seamlessly share and use data across different systems. The CMS Interoperability Framework could be emerging as a pivotal force driving this change. But there are other forces at play. By emphasizing shared standards and collaboration among patients, providers, payers, and digital health technologies, these forces are poised to evolve the health tech ecosystem.
Yet, even as some healthcare organizations adopt robust data exchange pathways, the ultimate goal, the last mile as it were, semantic interoperability, remains out of reach for many. While data exchange has improved, the next challenge is making that data complete, meaningful, and actionable
Below, we’ll explore core aspects of the CMS Interoperability Framework and other federal actions, the connection to semantic interoperability, and why high-quality data underpins the digital transformation of healthcare.
Understanding the CMS Interoperability Framework
The CMS Interoperability Framework serves as a voluntary roadmap for organizations committed to advancing healthcare data exchange. This framework prioritizes a patient-centered approach and encourages participation from all healthcare stakeholders. By focusing on standardization and enabling technologies, CMS aims to foster seamless collaboration across the health tech ecosystem. Early adopters span the healthcare ecosystem with promises to share data and build patient-facing apps in three topical areas.
The goals of this initiative are in line with the RFI on the Health Data Ecosystem that the CMS and ASTP released earlier this year. This RFI signaled the Federal Government's intent to cultivate a collaborative digital health ecosystem that builds on prior efforts like Blue Button 2.0 and Data at the Point of Care.
Key components of the CMS Interoperability Framework
- Patient empowerment: A defining features of this framework is empowering patients with access to their complete medical data. Built on digital identify and consent management principles, the framework ensures individuals have direct control over their information. Patients can make informed decisions, share data seamlessly with their providers, and engage more actively in their care.
- Provider access at the point of care: The framework supports providers with access to critical patient information through interoperable digital tools. Such access reduces administrative burden, aids clinical decision-making, and ensures continuity of care. Providers must ensure that they are accessing the information for treatment purposes only.
- Data availability protocols: Adopting standards like FHIR APIs (Fast Healthcare Interoperability Resources) and USCDI (United States Core Data for Interoperability) ensures that data is exchanged in compatible formats. By 2026, Organizations that attest to alignment with the CMS Interoperability Framework are expected to comply with its standards and undergo review.
Additional federal actions bolstering FHIR adoption
The CMS Interoperability Framework complements several federal initiatives:
- The ONC’s 2020 Cures Act Final Rule and the complementary CMS Interoperability and Patient Access Final Rule both introduce the need to capture and share data using the United States Core Data for Interoperability and FHIR-based APIs.
- TEFCA, introduced in the 2020 Cures Act and Final Rule, and implemented in December 2023, ushered in a new era of nationwide exchange of data.
- The 2024 CMS Interoperability and Prior Authorization Final Rule promotes the use of FHIR to streamline prior authorization processes while improving patient and provider experiences.
- The ASTP/ONC HTI-4 Rule emphasizes prescription drug cost transparency and focuses on prior authorization using the Da Vinci implementation guides.
Each of these and the new CMS interoperability Framework underscores a shared goal, each focusing on important use cases, but they also reveal a significant limitation. Without semantic normalization, the data exchanged, even using FHIR, often lacks standardization and usability, limiting its potential to improve outcomes.