When data sharing moves from vision to reality, it can create fresh friction points as entities establish new boundaries or maintain old ones, use and access is defined and redefined, and policies evolve. Despite a feeling of turbulence, this disruption is a normal part of growth and transformation. Here’s what healthcare entities should know about the maturing landscape, what to actually be concerned about, and the next stage of healthcare data evolution as we know it.
What holds true
The explosion of AI-powered healthcare tools, federal guidance, and countless health apps and wearables such as remote patient monitoring devices is redefining healthcare data, including who creates it, accesses it, and shares it. One major difference between sharing your healthcare data between your smartwatch and smartphone or even your doctor is that consumer tech relies on individual consumer agreements. In contrast, healthcare entities that exchange data at a national scale rely on the Trusted Exchange Framework and Common Agreement (TEFCA). TEFCA was designed to establish a foundation of trust and alignment for entities engaged in healthcare data exchange. It supports a large range of organizations that collect and share data, including health information networks (HINs), health information exchanges (HIEs), providers, health systems, federal agencies, public health agencies, payers, health IT developers, and individuals, which all connect through a limited number of Qualified Health Information Networks (QHINs). The vision? All information is available anywhere at any time to patients and qualified providers alike, making health information accurate, complete, relevant, and usable.
The messy middle
Between the vision and reality is where we are today: determining what it means to ensure that data is shared safely, responsibly, and with the right people at the right time. There are a few concerns and risks currently dominating the landscape. To start, an integrated approach to health (think: social services, behavioral health, etc.) that benefits from information with entities, such as community-based organizations (CBOs) or community clinics, can be perceived as a risky proposition, particularly since only some entities are governed by HIPAA and others choose to follow HIPAA guidelines. This cross-sector exchange and the resulting secondary use (i.e., how would this information be used by a clinic’s partners?) can lead to only sharing minimal information and overly complicated use agreements. The second major concern is grounded in compliance standards. As policy is translated into the real world, it can raise new questions about what is required vs. what is not covered, opening up organizations to risk. This can slow enthusiasm for participation, invite more attorneys into data sharing contracts and agreements, and hamper the very “good faith,” trust-based interactions that are required for innovation and integrated care.
Avoiding the doom spiral
Interoperability can feel like it’s getting caught in a vortex that could slow down progress and bring cross-sector sharing to a halt. What’s important to remember is that this is just the next stage of growth.
While interoperability has been in the headlines for good news and bad over the last 18 months, it has a long history behind it and more momentum than the eye (and headlines) can see. What makes this period of time unique — and as demonstrated by many of the conversations happening in the halls of HIMSS 2026 — is that we have already accomplished the technical standards required to make interoperability possible. Now, we’re progressing to usability, which requires trust to move forward smoothly. With TEFCA serving as the foundation for this vital characteristic, it’s still up to the entities engaged in data sharing to embody it, from the way data is technically handled to the trust put in providers and clinicians to access and use this information appropriately.
Scaffolding trust in interoperability
The goal of trust in interoperability isn’t to replace the compliance frameworks, participation mandates, standards, and industry precedents that make a complex ecosystem functional. It’s to allow all entities to move flexibly from one milestone to the next, together. This work includes remaining clear-eyed and critical of even the technical foundation that interoperability is built on.
For instance, in February 2026, the Office of the National Coordinator for Health IT (ONC) and the Recognized Coordinating Entity (RCE) asked for comments related to the TEFCA treatment standards and the corresponding vetting process (or the definition of who can access information for treatment reasons). With 14,214 organizations live on TEFCA representing more than 79,000 unique connections, the implications of these recommendations are expansive. Engaging with these proposed rules is a critical step to build trust in the community, and additional considerations to de-duplicate qualification requirements, reduce restrictions on already-covered entities, and simplify vetting and transaction processes are all steps that could improve usability while minimizing administrative strain.
In a perfect world, standards and operating procedures will be anchored by trust and joint responsibility. This includes influencing governance and structures that favor shared liability, moving the entire data sharing community out of being incentivized to blame one another and toward collective stewardship. It should also include transparent data use norms that allow the community to demonstrate and see how policies translate to the real world. Finally, the community governance (as currently demonstrated by the current TEFCA development process) can serve as a model for a future that will one day include cross-sector exchange. This ideally will include entities that provide integrated support to patients, ensuring that access to the best care is grounded in accurate, complete, and relevant information.
Accelerating high-quality outcomes
The very public challenges afoot are a natural byproduct of bringing policies, governance, and standards to life. Instead of allowing it to bog down progress, we should think of it as productive conversations that lead to downstream clarity — creating more predictable enforcement, standards, and anti-data blocking precedents that allow us to move faster downstream. With predictability being a defining characteristic of a trustworthy interoperability community, decisions can be used to streamline how entities interact with more confidence, speed, and innovation.
As we look to the next stage of interoperability, here’s what we expect to dominate the headlines in the years if not months ahead: less about the woes and more about the real-world outcomes interoperability is generating. Interoperability’s technical capabilities will be the very thing fueling value-based care to population health improvements, public health insights that deliver productive policy, and comprehensive, whole person care. Trust in the process will allow us to help trust in interoperability to make these gains a reality.
Photo: LeoWolfert, Getty Images
Paul L. Wilder, Executive Director of CommonWell Health Alliance, is leading the organization as it empowers clinicians, practitioners and individuals with interoperability services via its robust, nationwide network. With more than two decades of experience in health IT, Paul is a passionate advocate for transforming the health care delivery system nationwide.
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