Healthcare Interoperability

State of play.

• The Trump administration's 2026 Unified Agenda explicitly prioritizes health data interoperability standards as part of a broader deregulatory push across CMS, HHS, and DEA, with major Medicaid rules expected imminently .
• A growing practitioner argument holds that technical interoperability has outpaced operational accountability — data moves at scale through TEFCA and HIEs, but discharge follow-through, medication reconciliation, and care transitions remain fragmented in post-acute and behavioral health settings .
• Four topics in this cluster carry no substantive editorial content yet — the diagnostic imaging interoperability RFI, the 2026 ASTP annual meeting takeaways, and the VA Community Care Network procurement are named but not yet populated .
• For counsel advising health systems, post-acute providers, or payers, the practical baseline is a two-track risk: regulatory exposure from pending CMS interoperability rulemakings, and an emerging liability theory that exchanging records without operationalizing follow-through creates a false sense of coordination.

Where things stand.

• The 2026 Unified Agenda makes health data interoperability a named regulatory priority. CMS is expected to release major rules in the near term, and the agenda signals independent regulatory action on interoperability standards without waiting for legislation .
• HIPAA security standards are in the deregulatory crosshairs. The Unified Agenda targets HIPAA security rule revisions alongside telehealth provider registration and Medicaid managed care — meaning the compliance baseline for data exchange may shift .
• The operational gap between data exchange and care coordination is documented and gaining traction. The Watershed Health commentary identifies that post-acute care settings, community organizations, and employers still rely on fax and phone for care transitions despite technically feasible EHR-based exchange — a gap that connects to readmission liability and value-based care penalties .
• Information-blocking rules have made data exchange technically feasible but have not mandated accountability for action on received data. The gap between exchange obligation and follow-through obligation is the current frontier for compliance and malpractice exposure .
• Diagnostic imaging interoperability and longitudinal patient records are on the regulatory radar via a pending RFI, and the 2026 ASTP annual meeting has generated practitioner takeaways — both areas to watch as the corpus develops .
• VA Community Care Network procurement is entering a new phase, with interoperability requirements likely embedded in contract specifications .

Latest developments.

• The Trump administration's 2026 Unified Agenda names health data interoperability standards as a priority regulatory action, with CMS expected to release major rules in the near term .
• Watershed Health CEO Effie Carlson publishes commentary arguing that care transition gaps persist despite nearly 500 million health records exchanged through TEFCA and HIEs since 2008, framing the failure to operationalize data sharing as an emerging liability and compliance risk .

Active questions and open splits.

• Where does the information-blocking obligation end and the care-coordination duty begin? Federal rules require data exchange; no parallel federal mandate requires that receiving providers act on exchanged data. Whether that gap generates malpractice or regulatory liability under value-based care models is unsettled .
• How will the Unified Agenda's HIPAA security revisions interact with existing interoperability mandates? Deregulatory changes to HIPAA security standards could loosen the compliance floor for data exchange at the same time CMS is pushing interoperability expansion — creating a potential tension in the compliance architecture .
• What interoperability requirements will the VA Community Care Network contract embed? Federal procurement contracts are a leading indicator for interoperability standards that later migrate to private-sector expectations .
• What did the 2026 ASTP annual meeting signal about enforcement priorities and certification standards? ASTP's annual meeting typically previews ONC's near-term enforcement and certification posture — the takeaways from this cycle are not yet in the corpus .
• Will the diagnostic imaging interoperability RFI produce binding standards or remain advisory? The RFI's focus on longitudinal patient records suggests a potential expansion of interoperability obligations beyond current EHR-centric frameworks .

What to watch.

• CMS rule releases in the near term implementing the Unified Agenda's interoperability and HIPAA security priorities — these will reset the compliance baseline for health systems and payers .
• Whether the diagnostic imaging interoperability RFI produces a proposed rule or binding guidance, and how it addresses longitudinal record obligations .
• ASTP enforcement actions or certification decisions following the 2026 annual meeting .
• Whether the care-transition liability theory gains traction in malpractice litigation or CMS audit findings — the Watershed Health commentary is the leading edge of an argument that health systems should be tracking .
• VA Community Care Network contract award and its interoperability specifications as a benchmark for federal procurement standards .