By Dhaval Shah and Swanand Prabhutendolkar

Interoperability rules have been changing quickly, with numerous iterations since January 2020 alone. Even as we all have been experiencing uncertainty, upheavals, and loss from the COVID-19 public health crisis, surprising momentum toward interoperability has occurred in key areas of healthcare delivery, making rapid progress in just a few short months, the increased use of direct protocols to report hospital-acquired infections to the CDC and tackling telemedicine challenges with lightweight SMART-on-FHIR apps.

In the midst of the pandemic, the Centers for Medicare and Medicaid Services (CMS) issued the final interoperability rule in March, with extended timelines announced this summer that delay implementations to next year or beyond.

Two rules in particular are noteworthy. First, the CMS Interoperability and Patient Access Rule created new policies to “give patients access to their health information and move the healthcare system toward greater interoperability.”

Additionally, the ONC Trusted Exchange Framework, part of the 21st Century Cures Act, was issued by the Office of the National Coordinator for Health Information Technology (ONC) in April. This ruling was designed to “help enable nationwide exchange of electronic health information (EHI) across disparate health information networks (HINs).”

Both regulations stand to improve how healthcare organizations and patients access, use, and share electronic health information (EHI), and pave the way for more sophisticated and seamless data exchange.

That’s good news, since the need for more connected and secure ways to exchange data is paramount as the world responds to one of the largest health crises it has ever faced. Now is the time to continue to improve and escalate the need for real-time data exchange.

As organizations continue to adapt and adjust to today’s shifting realities, it’s important to extend existing interoperability setups to help ensure systems are prepared for the tsunami of information it will need to exchange.

Creating these existing interoperability efforts comes with a variety of known, persistent challenges. For example, there is a need to manage various data and file formats by numerous vendors and navigate different styles of data exchange. So far, these multiple and varying standards haven’t made it easy. The use of custom Z-segments and arbitrary mapping of HL7 fields, lack of conformance and different exchange and legacy coding methods has led to multiple initiatives to standardize data exchange over the years.

Interfaces and communication technologies vary widely. Currently, the lack of unifying capability in the form of a single patient ID makes it challenging to match an individual’s records across payers, providers, and facilities. Additionally, there’s no single standard for data quality across the industry or across the multitude of systems, such as electronic health records.

In spite of these challenges, moving forward to strengthen your organizations’ approach to interoperability is a step in the right direction—one that can help your organization quickly adapt and prepare you for a successful future.

Five Steps to Help You Prepare for Interoperability Timelines

Here are five key steps you can take to help ensure your organization is adequately prepared to meet pending interoperability timelines—specifically, CMS’ Interoperability and Patient Access rule, which now has a deadline of July 2021. Reviewing and strengthening your data foundation and governance now will provide the optimal path forward.

1. Move towards a single data strategy with strong governance built around a common organizational language, including diligence around managing complex data security and privacy needs.

Doing so can improve your organization’s ability to work with large amounts of data at high speeds using features such as replication, horizontal scalability, and high fault tolerance.

2. Create an enterprise-wide digital strategy and consider offering more data from more sources.

Consider a platform approach to help ensure data is able to live in a single well-governed source that utilizes consistently defined terms and concepts. Over time, this allows the organization to go beyond the standard healthcare sources, such as claims, HL7, and CCDA, to also include historically cost-prohibitive data, such as benefit information and unstructured data.

3. Assess how and when you will begin to adopt bidirectional data exchange.

Develop an approach that will increase your organization’s ability to conduct bi-directional data exchange and evaluate whether you will implement a new solution or build a bespoke solution on your own.

4. Begin to adopt the FHIR standard for healthcare data exchange.

The current version, 4.0, was published in October 2019 by HL7. There are a variety of helpful resources to assist, including the FHIR Interface Guide, which describes the key requirements, such as the FHIR API gateway and server setup, API development and configuration, USCDI-compliant FHIR profiles, FHIR data mapping and parsing, and security (identity and access management) integration.

5. Work with care teams to review program coordination and prepare for delivery of patient-specific information.

Begin to prioritize which data structures need to be member- and/or patient-centric, in preparation for giving patients more direct access and control. Identify the goals, gaps, and short- and long-term approach to meet the defined rules and guidelines.

Ability to navigate continued pandemic-related response benefits from strong data foundation

The next few months and even years will continue to herald great change in healthcare delivery, both as a result of pandemic-related challenges and to adapt to the shifts once the crisis passes. Getting started using these recommended steps is one way to help strengthen your data foundation and begin to make significant progress in preparing your organization for greater interoperability and support towards digital health.


Dhaval Shah ( is senior vice president, medical technology, CitiusTech. Swanand Prabhutendolkar ( is senior vice president, healthcare data management, CitiusTech.