CMS released its Interoperability Framework in 2025 as a path forward for EMRs to finally make seamless data exchange a reality. The vision is clear: empower patients and providers by building a connected infrastructure that’s open, standards-based, and rooted in execution instead of theoretical debate.
What’s different this time is the tone. CMS isn’t issuing a mandate or a rule; they’re offering a collaborative blueprint, complete with criteria and shared infrastructure. Anyone, big or small, can take the pledge to become a CMS-Aligned Network. That invitation includes networks, EHRs, payers, providers, and digital health apps. It feels like all the right components: faster momentum, patient-first thinking, and modern technology that meets the industry where it is.
But while it’s being framed as voluntary, it may not feel voluntary in practice.
A gentle pledge with hidden requirements
The pledge sounds like a gentle opt-in. There’s no requirement to meet every standard on day one, just a commitment to work toward doing the right thing. That sounds great. But to actually participate in the network, you have to meet a baseline level of interoperability.
That’s not surprising for organizations that have been building toward this for over a decade. Epic, Cerner, and Athena have had regulatory and financial incentives to enable data exchange since Meaningful Use. They’ve already been meeting or exceeding this level of interoperability for a long time. But that hasn’t been the case across all sectors of healthcare.
If the goal is to create a complete patient experience with a unified login, provider directory, and seamless access to data, then a lot of critical parts of the care ecosystem are at risk of being left behind. Post-acute care, outpatient rehab, and behavioral health providers were not given the same financial runway to prepare. They’re now expected to meet this bar out of their own resources. So while the framework says it’s all carrot and no stick, for many, it feels like all stick and no carrot.
Participation gaps will disrupt the patient journey
We’re already seeing the shift toward care outside the hospital. Healthcare systems are doing everything they can to keep patients out of inpatient settings or move them through those settings more quickly. Patients are moving to rehab, home health, and outpatient care as quickly as possible, and those areas are seeing major growth.
But the networks that are ready to participate in this framework right out of the box are mostly organizations tied to the inpatient environment we’re trying to de-emphasize. They’ve received funding and attention. They’ve been the stars of interoperability programs. The rest of the healthcare ecosystem hasn’t had that benefit.
So even though CMS’s intent is right, and they’re taking a much-needed stance, the outcome is uneven. If your EMR doesn’t participate, you may not show up in the CMS provider directory. And if that directory becomes a critical tool over the next five to 10 years, this will influence how patients find providers and how providers make technology decisions.
Even if it’s not officially required, the cost of not participating will grow. Maybe not today, maybe not this year. But over the next few years, this will have real business and operational consequences. Participation may affect referrals, visibility, and network strength.
A familiar starting point with far-reaching implications
This is a familiar moment. It starts small. Then systems get built around it. If you remember Meaningful Use, you’ve seen how a simple goal can spiral into a massive web of complexity. That program became quality-based care. Then came document exchange. Then QHINs, HIEs, and TEFCA. We’ve been heading toward this for over a decade.
The Interoperability Framework is a continuation of that journey. It’s about patient data exchange and access first. But it’s also setting the stage to make health insurance less complicated for providers, and to support more patient-facing apps. There’s already a vision for what those apps might look like, which may include killing the clipboard, enabling conversational AI, and improving chronic disease management.
Some of those priorities make perfect sense. Nobody wants to fill out the same form five times every time they see a different doctor. We want to eliminate that redundancy for patients and for clinicians. Others are harder to unpack. Most large health systems already have conversational AI solutions. And it’s unclear whether CMS plans to build an app marketplace or just set standards for others to follow.
Either way, it’s clear this is another step toward centralizing patient access. CMS has even said they envision a future where one digital credential could let a patient access all their records across specialists, primary care, and pharmacy portals, without needing to remember a dozen usernames and passwords.
What providers and tech vendors need to understand today
The onus will be on EMRs to participate. But providers will need to push their EMRs to prioritize participation. This isn’t just about compliance. It’s about what patients are going to expect in the near future.
Here’s what you should know if you run a rehab therapy clinic:
- Patients may start asking where their notes are. If they’re using a CMS-aligned app and your EMR isn’t connected, they’ll ask why.
- Patients may assume consents they’ve already given through the CMS ecosystem will apply everywhere. That can create friction if your EMR can’t interpret or honor those consents.
- If you’re not listed in the CMS directory, that could affect referrals. Over time, that visibility gap could impact patient flow.
This is another step in a long-term movement. Health data portability has been a topic for years. This is just another mechanism to get us there. CMS is trying to make it work. And even if the system doesn’t exist yet, we should all get very comfortable with the idea that it will and soon.
Photo: Issarawat Tattong, Getty Images
Elisabeth Brown is the Principal Product Manager leading AI & Clinical Solutions at WebPT, the leading rehab therapy platform.
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