We’re Done Waiting: Interoperability Must Move from Policy to Execution

The CMS Interoperability Framework is a voluntary blueprint for modern health-data exchange—not a new regulatory mandate. Its 26 criteria span five domains: patient access and empowerment; provider access and delegation; data availability and standards compliance; network connectivity and transparency; and identity, security and trust.

The intended end state is practical: patients retrieve structured and unstructured health information through applications of their choice; strong digital identity reduces repeated portal registration; providers retrieve complete treatment records and delegate transactions to trusted technology partners.

By July 4, 2026, aligned networks are expected to support FHIR APIs consistent with US Core and USCDI v3 or later, including terminology compliance using LOINC, RxNorm and SNOMED. Networks are also expected to publish participants and endpoints and report successful and unsuccessful queries. Delivery therefore depends on coordinated action by networks, providers, EHR vendors, payers and patient-facing applications.

The limitation is explicit: participation is voluntary, several criteria are described as visionary, and implementation guidance for less mature areas still requires development. A blueprint can align an ecosystem, but it is not evidence that interoperability has already been achieved.