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FHIR Interoperability: The Next Step to True Health Data Liquidity

two healthcare workers examining something on a laptopAchieving data liquidity in the healthcare industry has been a goal for more than 50 years, or since the first digitization of health information. This concept means that restricted health data is accessible to any authorized user on demand once it’s been entered into any system of record. 

So why are will still discussing the promise of data liquidity in the context of interoperability today? And further, why are we not discussing the promised revolution of full health data availability, both when and where it is needed? That history is worthy of a much fuller discussion. 

There are four key considerations when evaluating the success of interoperability efforts:  

  1. Economic or regulatory incentives  
  2. Standardized data formatting 
  3. Data security 
  4. Data ownership   

Regulatory incentives, including those provided through the HIPAA Administrative Simplification and Enforcement Rule and the HITECH Act, have made significant strides in addressing administrative data formatting and data security. This is primarily due to the implementation of HL7 core transaction sets. However, the industry still falls short of truly interoperable clinical data and information exchanges that address current market realities of digital health, consumer enablement, mobile health, and medical device data.  

The next step in achieving market realities is industrywide adoption of the next version of HL7, which is known as FHIR (Fast Healthcare Interoperability Resources), and the implementation of the Common Health Plan Consumer Data Set (CPCDS) standard. 

FHIR promises to address many of the core data liquidity barriers to success through the following ways: 

  • The CPCDS formatting standard 
  • Defined data access
  • Information blocking security definitions provided by the interoperability provisions of the 21st Century Cures Act 

The regulatory incentives also cover both health plans and providers. So, when can we expect widespread adoption? The following table provides the most recent key enforcement deadlines for the required health plan standards:  

21st Century Cures Act Health Plan Interoperability Deadlines

CMS Mandate  Enforcement Deadline 
Patient Access API (MA & CHIP)  July 1, 2021 
Provider Directory API (MA & CHIP)  July 1, 2021 
Improving the Dually Eligible Experience by Increasing the Frequency of Federal State Data Exchanges   

April 1, 2022 


To avoid penalties, health plans must act now to meet these compliance deadlinesAt Microsoft, we are using early investments in our Azure API for FHIR(r), as well as our partners’ compliance methodologies, investments, and implementation resources, to assist health plans in meeting these compliance deadlines. 

Successful health plans will go beyond compliance as they seek to use this new data liquidity to advance the health of their members. Mark Scrimshire, Chief Interoperability Officer, CMS Blue Button Innovator and Entrepreneur-In-Residence for Onyx Technology, emphasizes the importance of health plans adopting interoperability in his blog, What do the CMS/ONC Interoperability Mandates really mean for Health Plans?:  

“It’s pushing towards consumers having a longitudinal health record. I think the health plans that really embrace the new regulations, thinking beyond just compliance with the mandate and looking at how interoperability can help their business, they’re the ones that are going to win.” 

So, welcome to the next major step towards true health data liquidity. It is guaranteed to be an interesting journey. 

Discover how Microsoft’s Azure API for FHIR(r) can help health plans meet compliance deadlines and enhance care management capabilities for your organization.