The Rules Are Changing. We’re Already at the Table.

Prior authorization has frustrated providers, payers, and patients for decades. Phone calls to utilization review departments. Faxed documentation. Multi-day waits while care is on hold. The administrative cost alone runs into the hundreds of billions annually across the healthcare system, and the human cost is harder to quantify but just as real.

Over the last two years, federal regulators have moved decisively to change that. And the standards bodies that underpin how healthcare data actually moves have been working even longer to build the infrastructure those regulations require.

At UHIN, we haven’t been watching this from the outside. We’ve been inside the rooms where implementation gets figured out, and we’ve been there by design.

Here’s what’s shifting, why it matters to you regardless of your role, and what it means to have a partner who was already invested in this work before it became mandatory.


What’s Changing, Rule by Rule

CMS-0057-F: Interoperability and Prior Authorization

Finalized in January 2024, CMS-0057-F is the most significant overhaul of prior authorization workflows in HIPAA history. It requires Medicare Advantage, Medicaid, CHIP, and qualified health plans on the federal exchanges to implement four FHIR-based APIs: Patient Access, Provider Access, Payer-to-Payer, and Prior Authorization. Full API compliance is due January 1, 2027.

Operational requirements came first. As of January 1, 2026, payers are required to issue standard prior authorization decisions within seven calendar days and expedited decisions within 72 hours.¹ Payers also began publicly reporting prior authorization metrics (approval and denial rates, average decision times, appeals outcomes) starting March 31, 2026, covering calendar year 2025.²

On the technical side, the rule centers on HL7 FHIR R4 infrastructure and SMART on FHIR for authentication. The Da Vinci Project’s implementation guides define the workflows those APIs are expected to support. The Coverage Requirements Discovery (CRD), Documentation Templates and Rules (DTR), and Prior Authorization Support (PAS) guides collectively describe how a provider system can determine whether authorization is needed, surface documentation requirements, and submit a request without leaving the clinical workflow.³ These are the standards the industry is actively working to implement, and organizations are at different stages of readiness across all three.

There’s also a meaningful shift in how FHIR and X12 coexist. CMS issued enforcement discretion allowing payers to implement a FHIR-only Prior Authorization API without being required to also use the X12 278 transaction.⁴ For the first time in HIPAA history, FHIR can function as a standalone path rather than a complement to EDI. The 278 remains valid, and many real-world implementations will use a hybrid model where FHIR faces the provider side and X12 handles the back-end translation.

CMS-0053-F: Claims Attachments

Finalized March 24, 2026, CMS-0053-F establishes the first-ever HIPAA-adopted standards for healthcare claims attachments. It goes into effect May 26, 2026, with a compliance deadline of May 26, 2028.⁵

For decades, claims-related clinical documentation (medical records, imaging, lab results, clinical notes, telemedicine visit documentation) has moved via fax, mail, and payer-specific portals. This rule requires payers to support standardized electronic attachment transactions, though payers may continue accepting other forms of submission if they choose to. In practice, many payers today already discourage or decline non-electronic methods, and this rule formalizes the electronic standard they must support. Specifically, it adopts Version 6020 of the X12N 275 for provider-to-payer transmission of supporting documentation and the X12N 277 for payer requests to providers, along with HL7’s Consolidated Clinical Document Architecture (C-CDA) for structuring the clinical content inside those transactions.⁶

One thing to note: CMS did not finalize prior authorization attachment standards in this rule. That question is still open, with HHS continuing to evaluate how FHIR-based workflows, X12, and C-CDA should align. A CMS listening session in December 2025 addressed replacing the X12 278 with HL7 FHIR under the exception process.⁷ Stakeholder input is still actively shaping what comes next.

X12 Version 8060: The Next HIPAA Transaction Standard

Version 5010 has been the HIPAA-mandated X12 standard for administrative transactions since 2012. X12 published its 008060 EDI Standard in January 2025 and completed the full set of 008060 implementation guides for all HIPAA-mandated transactions in September 2025. The updated guides cover claims (837), eligibility (270/271), claim status (276/277), remittance (835), enrollment (834), and premium payment (820).⁸

X12 has formally recommended to the National Committee on Vital and Health Statistics (NCVHS) that 008060, along with its XML representation, be adopted.⁹ Version 5010 remains the current mandated standard while federal rulemaking proceeds. WEDI, as an official advisor to HHS, has been conducting its own Federal Policy Consultation process to gather industry input on the impacts, costs, and timing of the 8060 transition, with findings submitted to HHS.¹⁰ HHS convened an additional listening session with the Designated Standards Maintenance Organizations (DSMOs) and WEDI on July 1, 2026, specifically to gather perspectives on the proposed 5010-to-8060 transition; that feedback will inform future HIPAA Administrative Simplification rulemaking.¹¹

X12 has also launched a 2026 education series to help implementers understand what’s changing and prepare their systems before any mandate takes effect.¹²

For organizations managing EDI workflows, this transition will eventually touch every major transaction type you process. Now is a reasonable time to start asking questions and building familiarity with what’s different in 8060.


It’s tempting to think of prior authorization modernization as a simple point-to-point story: EHR sends a FHIR bundle, payer system responds, authorization decision arrives in minutes. That’s the goal. The path there is more layered.

Most providers don’t have direct FHIR connections to most payers. Many payer systems aren’t yet equipped to receive FHIR-based prior authorization requests natively across their full network. The translation work, routing between networks and managing acknowledgments, is precisely what clearinghouses are built to handle.

The HL7 Da Vinci Prior Authorization Support implementation guide makes this explicit: clearinghouses are one of the designated intermediary roles responsible for ensuring HIPAA transaction compliance while FHIR operates on the provider-facing side.¹³ The X12 handling happens in what the Da Vinci guide calls a “black box,” a service that the submitting system doesn’t need visibility into. That service is often a clearinghouse.

This isn’t a workaround. It’s the intended architecture for how hybrid environments function during the transition from legacy EDI to FHIR-native exchange. Getting the translation layer right, and getting it right across networks rather than just within individual point-to-point connections, is where the real implementation work lives.


Where UHIN Fits In

UHIN isn’t simply tracking these changes and updating our systems to match. We’re actively involved in building the frameworks the industry will follow.

Da Vinci Trebuchet: Clearinghouse-to-Clearinghouse Prior Authorization Pilot

In early 2025, UHIN was selected as a participant in the Da Vinci Trebuchet Clearinghouse-to-Clearinghouse (CH-to-CH) Prior Authorization Pilot, launched by the Cooperative Exchange in collaboration with the HL7 Da Vinci Project. The cohort includes eleven clearinghouses, including Waystar, Optum, Availity, and Veradigm, working to test whether FHIR-based prior authorization transactions can actually be operationalized across clearinghouse networks rather than just within individual point-to-point connections.¹⁴

The pilot is validating hybrid X12 and FHIR translation workflows that reflect how the industry actually operates today. The outcomes include a functional prototype, a clearinghouse implementation playbook, and concrete recommendations for improving the underlying standards including Da Vinci, FAST Implementation Guides, and X12. When those recommendations get made, UHIN will have helped shape them.

Utah Statewide FHIR Interoperability Pilot

UHIN is also a central participant in Utah’s statewide FHIR interoperability effort through the One Utah Health Collaborative, with clinical data exchange and prior authorization as the two primary use cases. UHIN has contributed patient attribution data, connectivity infrastructure, and coordination across payers, providers, and public health stakeholders working toward a shared FHIR-based ecosystem across the state.¹⁵ UHIN’s CTO participated in Civitas’s FHIR Deep Dive Series in early 2025 to share progress on that work with a national audience.

The CHIE on FHIR, Already Live

In late 2024, UHIN launched a modernized Clinical Health Information Exchange (CHIE) portal built on HL7 FHIR, supporting data sharing across 33 of 36 short-term acute care hospitals in Utah. This wasn’t a pilot or a roadmap commitment. It’s in production.¹⁶

Active Standards Participation

UHIN is a recognized Standards Development Organization with ongoing participation in national electronic transaction committees. We attend X12 standing meetings, engage with HL7 workgroups, and track NCVHS recommendations and comment cycles. When CMS convened its December 2025 listening session on the question of replacing the X12 278 with HL7 FHIR, the voices of organizations like ours were part of what informed that conversation.¹⁷


For EDI and revenue cycle teams: The 5010-to-8060 transition is not a mandated deadline yet, but the implementation guides are published, X12 is running education sessions now, and rulemaking is in motion. Getting familiar with what’s changing before the deadline appears is time well spent. Start by asking what’s different in 8060 for the specific transaction types you handle most.

For payers: The January 2027 FHIR API compliance deadline is closer than it looks once you account for integration timelines, testing cycles, and the organizational lift of standing up four APIs while also meeting the operational requirements that went live in January 2026. The clearinghouse layer handles the hybrid translation and provider-side connectivity that makes network-wide adoption feasible rather than theoretical.

For providers and revenue cycle leaders: CMS-0053-F requires payers to support standardized electronic claims attachment transactions by May 2028. Many are already moving in that direction now. Understanding what the X12N 275 and 277 transactions require, and how C-CDA structures the clinical content within them, will help you prepare for what your trading partners will eventually expect.

For compliance and technology leadership: The convergence of CMS-0057-F, CMS-0053-F, and the 8060 transition represents the most significant wave of HIPAA administrative simplification updates in over a decade. These rules interact with each other. The FHIR enforcement discretion for the 278 directly shapes how prior authorization attachment standards will eventually be decided, which CMS explicitly left unresolved pending further industry evaluation. Understanding how the pieces connect is as important as understanding each piece on its own.


UHIN has been at this for more than thirty years. We process hundreds of millions of transactions a year. We operate the nation’s only nonprofit clearinghouse network. We run Utah’s state-designated Health Information Exchange. And we sit at the table where standards get written, not just where they get implemented.

The regulatory changes coming into effect over the next two years reflect years of industry collaboration, standards development work, and pilot programs that UHIN has actively contributed to. We aren’t scrambling to catch up with what compliance requires. We’re already working on what comes after that.

If you want to talk through where your organization stands on any of this, we’re here for that conversation.


  1. CMS. CMS Interoperability and Prior Authorization Final Rule (CMS-0057-F) Fact Sheet. January 2024. cms.gov
  2. CMS. CMS Interoperability and Prior Authorization Final Rule (CMS-0057-F). January 17, 2024. cms.gov
  3. HL7 Da Vinci Project. Da Vinci Prior Authorization Support (PAS) FHIR IG v2.1.0. hl7.org
  4. CMS National Standards Group. HIPAA Transaction Enforcement Discretion. February 28, 2024. cms.gov
  5. AAPC. CMS Final Rule Standardizes Electronic Healthcare Data Exchange. March 31, 2026. aapc.com
  6. CMS. Administrative Simplification; Adoption of Standards for Health Care Claims Attachments Transactions and Electronic Signatures Final Rule (CMS-0053-F) Fact Sheet. March 2026. cms.gov
  7. CMS. Events and Latest News: Administrative Simplification. December 2025 Listening Session. cms.gov
  8. X12. X12 Publishes 008060 Versions of All HIPAA-Mandated Implementation Guides. September 2025. x12.org
  9. X12. X12 HIPAA Recommendation Letter. December 2025. x12.org
  10. WEDI. WEDI’s Federal Policy Consultation Process and X12 Version 008060. March 2026. wedi.org
  11. CMS. Events and Latest News: Administrative Simplification. July 1, 2026 Listening Session. cms.gov
  12. X12. Announcing the Kick-off of X12’s 008060 Education/Information Series. March 2026. x12.org
  13. HL7 Da Vinci Project. Da Vinci Prior Authorization Support (PAS) FHIR IG: Use Cases and Overview. hl7.org
  14. UHIN. Newsletter: January 2025 Issue. February 2025. uhin.org
  15. One Utah Health Collaborative. Advancing Interoperability in Healthcare: Utah’s Collaborative Approach. 2025. uthealthcollaborative.org
  16. UHIN. 2024 Year-End Recap. 2025. uhin.org
  17. CMS. Events and Latest News: Administrative Simplification. December 2025 Listening Session. cms.gov

Building on What Works to Connect Rural Utah

Advancing healthcare interoperability is not just about adopting the latest technology. It is about building sustainable systems that serve everyone, especially the communities that have their own unique needs and healthcare dynamics.

UHIN leadership recently returned from the Civitas Networks for Health Annual Fly-In in Washington, D.C., where 20+ leaders from health information exchanges, health data utilities, and regional health improvement collaboratives spent the week in 47 meetings on Capitol Hill. As Utah’s state-designated, nonprofit Health Information Exchange, UHIN was at the center of those conversations. The message Civitas members carried into every office was consistent: locally governed, community-led organizations are the implementation layer that turns federal policy into real-world results.

That message landed at exactly the right moment. The Rural Health Transformation Program (RHTP), a $50 billion, five-year federal investment created by H.R. 1 (the One Big Beautiful Bill Act), is moving from announcement to execution. Utah received $195.7 million in first-year funding, with up to $500 million expected over the life of the program. How states deploy those dollars between now and 2030 will shape rural healthcare for a generation.

Here is what stood out from our time on the Hill, and what it means for Utah.

The ongoing debate over the Rural Health Transformation Program (RHTP) funding centers on a critical question: who is best equipped to help alleviate the struggles of medicine?

While the $50 billion investment has drawn a surge of venture-backed firms, there is growing concern that these entities prioritize a five-year revenue “exit” over the generational stabilization required to fix medical deserts and workforce shortages.

The Civitas perspective argues that the most effective stewards of this capital are the local, mission-driven organizations already embedded in these communities. The rationale for prioritizing nonprofit HIEs, local providers, and public health agencies is rooted in the specific challenges they are uniquely qualified to address:

Why Local Stewardship Matters for Rural Challenges:

  • With 50% of rural hospitals operating at a loss, venture-backed models often cherry-pick profitable services. Local providers, however, focus on maintaining “unprofitable” but essential lifelines like maternity care, preventing the expansion of maternity deserts.
  • Private firms often rely on temporary “locum tenens” or remote-only solutions. In contrast, local agencies invest in the “grow your own” strategy, which is 5.4 times more likely to result in long-term physician retention in areas where 70% of the population faces primary care shortages.
  • Technology-only solutions from external contractors often fail because they ignore the low health literacy and poor broadband infrastructure prevalent in rural zones. Local HIEs and public health offices have the “boots on the ground” track record necessary to help an aging population navigate these digital hurdles.

A consistent thread across every conversation: state and federal dollars have already built much of the interoperability infrastructure RHTP now depends on. Health Information Exchanges, Health Data Utilities, All-Payer Claims Databases, and Quality Improvement Organizations are the connective tissue of community health data. They are already in place, they are governed by the people they serve, and they have decades of investment behind them.

The temptation with $50 billion of new federal money is to spin up something new and shiny. That impulse carries a real cost. Every dollar spent rebuilding what already works is a dollar not spent improving care in rural communities. Civitas members made the case repeatedly: the smart move is to strengthen and extend infrastructure that has been earned and tested over years, not to start over from zero.

This is the work UHIN has been doing in Utah for 30 years. The CHIE already moves clinical data securely across providers, payers, and public health partners. Our recently modernized, FHIR-aligned platform is ready to scale to meet the use cases RHTP is asking states to solve.

There was real candor in these meetings about how the program came to be. RHTP was created by the same legislation that carried significant Medicaid changes. Several Civitas members and Congressional staff spoke about deep regret tied to those cuts. To be clear, many in the room do not view RHTP as a win. They view it as the reality we now have to work with, and they were honest that the program, on its own, will not offset what rural hospitals stand to lose when the funding window closes in 2030.

That said, this is the world we are operating in. RHTP is the tool in front of us, and Utah received $195.7 million in first-year funding to put it to work. The question is not whether to engage. It is whether we engage thoughtfully enough that, five years from now, rural Utah is in a stronger position than it is today, not facing a steeper cliff.

That requires honesty about the math. It also requires the kind of long-game thinking that nonprofit, community-governed organizations are built for.

If there was one word that came up in nearly every meeting, on both sides of the aisle, it was sustainability.

Some rural organizations cannot even absorb the funding being offered. They do not have the bandwidth, the technical staff, or the procurement infrastructure to take a fire hose of federal dollars in a 12-month window and turn it into durable change. That is not a failure on their part. It is a structural reality of rural health that this program has to plan around.

The harder problem is what happens in 2030. Programs stood up on five years of grant money have a way of collapsing the moment the money stops. The work that will outlast RHTP is the work that fits inside infrastructure that was already going to be here, supported by sustainable funding models, governed by people accountable to the communities they serve.

What This Means for Utah

UHIN exists for a simple reason: Interoperability for all. Better costs. Better care. That mission predates RHTP, and it will outlast it.

With 25 of Utah’s 29 counties designated rural, and many rural Utahns traveling more than an hour for hospital care and four to six hours one way to see a specialist, the case for a connected, statewide data foundation is hard to argue against. Rural providers need clinical, claims, and public health information harmonized in a way that is computable, real-time, and actually useful at the point of care. That is the foundation that makes everything else possible, from analytics and clinical decision support to the AI applications coming next.

UHIN has spent three decades building toward that picture. We operate a FHIR-aligned, statewide exchange. We coordinate data every day across hospitals, EHR vendors, payers, and public health agencies. We know rural Utah, because we have been showing up there for a long time.

If RHTP is going to deliver what rural Utah needs, the infrastructure to do it does not need to be invented. It needs to be invested in.

Get Involved

If your organization serves rural Utah and you want to talk about how the CHIE can support RHTP-related initiatives, or about what a sustainable, trusted, connected data foundation looks like in practice, reach out to us here. We are ready to roll up our sleeves.

Borders, T. F., Youngen, K., & Cecil, J. (2026). The social determinants of health—Rurality and pregnancy. PMC – NIH. https://pmc.ncbi.nlm.nih.gov/articles/PMC13095225/ Cited by: 5

CDC. (2026). Geographic and sociodemographic patterns in prevalence of diagnosed diabetes, US, 2021–2024. Preventing Chronic Disease. https://www.cdc.gov/PCD/issues/2026/25_0288.htm

Frontiers. (2026). Digital twin virtual hospitals and rural health disparities: a six-country comparative study (2018–2024). Frontiers in Public Health, 14. https://doi.org/10.3389/fpubh.2026.1741438

Orimaye, S. O. (2026). Roadblocks to rural health: State transportation policies’ impact on health care access in Virginia’s rural communities. American Journal of Public Health, 116(2), 175–179. https://doi.org/10.2105/AJPH.2025.308285

Youngen, K., Cecil, J., & Borders, T. F. (2026). How 2026–2030 digital health policies impact access & patient engagement. Rural & Underserved Health Research Center Publications. https://digitalcommons.liberty.edu/cgi/viewcontent.cgi?article=3008&context=research_symp

UHIN Connects Utah: Building the Healthcare Network Our Communities Deserve

Graphic of data flowing through outline of Utah

A Shared Vision for Better Care

Infrastructure That Grows Stronger Together

The CHIE is a Shared Network

Common Governance Instead of Fragmented Agreements

Common Stewardship Instead of Vendor Dependency

Help Shape the Future

A New Chapter for the CHIE

Screen grab of CHIE dashboard
New CHIE Dashboard

Moving Forward, Together


UHIN Joins Utah Coalition to Improve CKD Detection & Care

UHIN Supports Statewide Effort to Improve Chronic Kidney Disease Detection and Care in Utah.

The Utah Health Information Network (UHIN) is collaborating with Comagine Health, the Utah Department of Health and Human Services (DHHS), and the One Utah Health Collaborative to relaunch the Utah Chronic Kidney Disease (CKD) Coalition. The coalition is focused on improving early detection and management of CKD across the state, using data to inform and support its strategies.


UHIN’s Utah Clinical Health Information Exchange (CHIE) is being used to help develop an alert system that will notify primary care providers when lab results suggest CKD but no diagnosis has been recorded. This alert system is designed to help improve follow-up and diagnosis rates—addressing the reality that 50% of individuals screened for CKD currently do not receive a formal diagnosis or follow-up care.

Additionally, UHIN is evaluating aggregate health data to support early intervention strategies based on methodologies from the National Kidney Foundation. The coalition is exploring the potential for DHHS grant funding to support the implementation of these strategies if data and provider interest support it.

The broader initiative also includes supporting local health districts and clinics in their CKD care efforts and expanding awareness and education around treatment options for end-stage renal disease, such as home hemodialysis and peritoneal dialysis.


UHIN’s involvement is centered on providing the data and tools needed to help health care partners make earlier, more informed decisions in CKD care.

Leveraging Data for Public Health: UHIN’s Role in Tracking Post-COVID Conditions (PCC) in Utah

UHIN’s Involvement in the Project

Collaborative Approach

In Conclusion


What is a Health Data Utility?

Image of a desktop computer with the Health Data Utility dashboard

There is a national trend of Health Information Exchanges (HIEs) evolving into Health Data Utilities (HDUs). What is a Health Data Utility? The Consortium for State and Regional Interoperability defines a HDU as “a locally governed, public-private resource providing a source of truth for robust clinical and non-clinical data” to benefit state and other members of the healthcare ecosystem by providing data.  

Much of the conceptualization of HDUs was done by Civitas Networks for Health, The Maryland Health Care Commission & CRISP, and the Consortium for State and Regional Interoperability. The HDU is the next phase for HIEs, recognizing that the data in an HIE is a valuable resource that can be utilized beyond just single patient lookup. It can be utilized for quality improvement, population health, research, and combined with other datasets for advanced analysis.  

Data is the Lifeblood of an Organization

There is a saying that data is the lifeblood of an organization. Data is critical to identify areas and populations of need, understand and describe current status, evaluate interventions, improve efficiency, inform decisions, discover and adapt to changing conditions, and drive innovation. The COVID pandemic highlighted both the need for data and to identify gaps in data accessibility. The federal government has been working for the past two decades to improve the collection and availability of data to improve health care through initiatives such as the Health Information Technology for Economic and Clinical Health Act (HITECH), the formation of the Office of the National Coordinator (ONC), the 21st Century Cures Act and its Information Blocking provisions, and the Trusted Exchange Framework and Common Agreement (TEFCA) for national health information exchange. HDUs provide the infrastructure for data accessibility.

What HDUs Can Do

Data is critical to identify areas and populations of need, understand and describe current status, evaluate interventions, improve efficiency, inform decisions, discover and adapt to changing conditions, and drive innovation. The COVID pandemic highlighted both the need for data and to identify gaps in data accessibility. The federal government has been working for the past two decades to improve the collection and availability of data to improve health care through initiatives such as the Health Information Technology for Economic and Clinical Health Act (HITECH), the formation of the Office of the National Coordinator (ONC), the 21st Century Cures Act and its Information Blocking provisions, and the Trusted Exchange Framework and Common Agreement (TEFCA) for national health information exchange. HDUs provide the infrastructure for data accessibility.

Necessary Conditions

Necessary conditions for a HDU are considered to be a shared vision, political will/state policy, broad stakeholder participation, multi stakeholder governance, a legal framework, mature use cases, data privacy and security, and secured funding. The American Language Exchange Council has developed model language for a Statewide Health Data Utility Act.  They believe that a “state health data utility can help achieve better patient outcomes, and improve overall health and wellbeing of the people of the state. It can also reduce the cost of healthcare services by creating a more seamless, transparent, and modernized approach to sharing health information. The health data utility will comply with all federal and state privacy laws and allow for an opt-out for patients who choose not to share their data.”

In Conclusion

UHIN established the Utah Clinical Health Information Exchange in 2007 to bring together a patient-centric, longitudinal record amongst disparate healthcare systems and organizations. We strive to make data accessible for better costs and better care. Evolving into an HDU, while also balancing patient privacy needs, is the next step.


Civitas Networks for Health invites public comment on the draft HDU Framework Supplement Version 1, which outlines critical updates to the existing Health Data Utility Framework. This supplement highlights actionable strategies for advancing health data governance, interoperability, and equity across states and regions.

Comment Deadline: January 31, 2025

Access the HDU Framework Supplement Version 1:

Comments: Feedback Form or via email to hdu@civitasforhealth.org


Unlocking the Potential of FHIR: An Overview of its Impact and Future

Doctor hands on tablet with hologram overlay of patient data

As the CTO of UHIN, I’ve seen firsthand the challenges and frustrations of trying to achieve seamless interoperability. Data silos, incompatible formats, and outdated standards have long hindered our ability to share information effectively. But HL7® FHIR® (Fast Healthcare Interoperability Resources) offers a glimmer of hope, a path toward a more connected and efficient healthcare ecosystem.

Understanding FHIR: A Paradigm Shift

FHIR represents a paradigm shift in healthcare data exchange. Unlike older standards like HL7 v2, which often resemble complex, rigid blueprints, FHIR is akin to a set of modular building blocks. These blocks, called “resources,” represent discrete units of healthcare information – a patient record, a medication order, a lab result, and so on.

The true power of FHIR lies in its flexibility. Resources can be combined and exchanged in various ways to suit specific needs. Need to share a patient’s medication history with a specialist? FHIR allows you to do that without sending the entire medical record. Want to integrate a new mobile app with your EHR system? FHIR’s web-friendly technologies make it easier than ever.

Dispelling the Myths: FHIR is NOT a Panacea

While FHIR offers immense potential, it’s important to be realistic about its limitations. It’s not a magic wand that will instantly solve all our interoperability woes.

First and foremost, FHIR is a standard, not a solution. It provides a common language for exchanging healthcare data, but it doesn’t address the underlying technical and organizational challenges that often impede interoperability.

Second, FHIR is not a plug-and-play technology. Implementing it requires careful planning, technical expertise, and collaboration among stakeholders. Organizations with legacy systems may face particularly daunting challenges.

Finally, FHIR doesn’t guarantee interoperability. While it facilitates the exchange of data, it doesn’t ensure that the data will be understood and used consistently across different systems. Achieving true interoperability requires not just technical compatibility but also semantic interoperability – the ability to interpret and apply data in a meaningful way.

The Benefits of FHIR: A Catalyst for Innovation

Despite its limitations, FHIR offers significant advantages over older standards. Its flexibility, ease of use, and strong community support make it a powerful catalyst for innovation.

By adopting FHIR, healthcare organizations can:

  • Improve data sharing: FHIR enables more granular and tailored data exchange, making it easier to share information with the right people at the right time.
  • Accelerate development: FHIR’s web-friendly technologies lower the barrier to entry for developers, potentially leading to faster innovation.

For example, UHIN’s Clinical Health Information Exchange (the CHIE)  is currently migrating to a new FHIR-enabled platform. Built on a highly scalable architecture, the platform allows for more efficient and secure sharing of data across enterprises.

The Road Ahead: A Strategic Approach to FHIR Adoption

To reap the full benefits of FHIR, healthcare organizations need to adopt a strategic approach. This involves:

  • Developing a clear roadmap: Start by defining your interoperability goals and identifying specific use cases where FHIR can add value. Transitioning totally functional workflows from older specifications to FHIR, just for the sake of using a more modern data structure, won’t create new healthcare outcomes on its own. We need to use FHIR when it’s appropriate and when it will provide the most advantage to our interoperability goals. 
  • Building a strong foundation: Invest in the necessary infrastructure, tools, and expertise to support FHIR implementation.
  • Collaborating with stakeholders: Engage with vendors, partners, and other stakeholders to ensure that FHIR implementations are aligned and interoperable.
  • Focusing on education and training: Ensure that your team has the knowledge and skills to work with FHIR effectively. While the FHIR structure can lead to an easier onboarding of software engineers, it also increases the complexity of a given use case by having multiple resources required to accomplish the same goal that a single CCDA may have solved previously. HL7 International offers online courses covering the fundamentals (for a price) and educational videos on its YouTube page here.
  • Embracing a culture of innovation: Foster a willingness to experiment and adapt as FHIR evolves. Many early adopters of FHIR were burned by the rapid change that occurred from version to version of FHIR. Knowing that there will be maturation of the standard is important to understand before starting an implementation. 

Conclusion: The Future of Healthcare Data Exchange is FHIR

FHIR is not a silver bullet, but it is a significant step forward in our quest for interoperability. By embracing FHIR and addressing the challenges it presents, we can unlock a wealth of opportunities to improve healthcare delivery, enhance patient outcomes, and drive innovation.

The future of healthcare data exchange is FHIR. Let’s seize this opportunity to build a more connected and efficient healthcare ecosystem.


The Power of Resilient and Redundant Healthcare Technology Systems

Redundancy and resilience are two foundational principles to ensure healthcare technology systems remain functional, particularly in the midst of challenges and disasters, like outbreaks and data breaches. This became apparent during the COVID-19 pandemic and recently in light of the Change Health Care incident. Establishing redundancy and resiliency in healthcare technology ensures sustained, comprehensive interoperability. This is critical particularly in healthcare, where any system failure can have serious consequences for patient care. As healthcare becomes more digitized and interconnected, the complexity and potential vulnerabilities of these systems also increase. This necessitates a stronger focus and shared responsibility to build resilience and redundancy into healthcare technology systems.

Resilience is defined as the ability to prepare for, manage (absorb, adapt and transform) and learn from shocks (source: National Library of Medicine). Given the interoperable nature of our healthcare ecosystem, resilience focuses on identifying and filling gaps between systems, networks, and connected ecosystems.

Redundancy is defined as provision of duplicate, backup equipment, processes, pathways or systems that immediately take over the function of existing functionality or business processes (source: Gartner). For instance, if a primary server fails, a backup server can take over, ensuring that patient data is still accessible and that critical healthcare services can continue. Following the Change Health Care incident, The American Hospital Association (AHA) made recommendations about “backup technology which renders the backups “immutable” — unable to be deleted, altered or encrypted.”

Building a resilient and robust healthcare technology system involves strengthening human resources, infrastructure, and technological capacities. This includes investing in technology training for healthcare workers and building robust and resilient IT infrastructure. It also means promoting strong primary healthcare interoperability, which heavily relies on interconnected data sharing for health data management, communications, and HIPAA-compliant claims management. This is specifically relevant in times of crisis.

For example, at the start of the COVID-19 pandemic, UHIN initiated real-time notifications from hospitals and labs in and around Utah that could be sent directly to healthcare providers, ACOs and care managers. This focus on interoperability enabled all stakeholders to monitor and coordinate care more effectively for their patients, especially those in greater need of physician intervention. Real-time notifications enabled participants to act swiftly, reduce manual labor, and access data from care partners more easily. UHIN continues to deliver COVID-19 lab result alerts today.

Building resilient and redundant healthcare technology systems is not just about investing in technology. It’s also about investing in the people who use these systems. Developing partner relationships is key to building resilient and redundant healthcare technology systems. By fostering collaboration and open communication, organizations can jointly tackle the complexities of healthcare technology, ensuring that systems are robust, adaptable, and capable of supporting seamless interoperability. Strong partner relationships also facilitate the sharing of best practices, innovative solutions, and technical expertise, thereby enhancing system resilience and redundancy. Ultimately, these partnerships contribute to a more reliable, efficient, and patient-centered healthcare technology ecosystem.

The Benefits & Challenges of Interoperability in Disaster Recovery

When it comes to interoperability, which refers to the ability of different systems and organizations to communicate and exchange information effectively, the healthcare ecosystem relies on maintaining seamless operations in times of success and disaster. There are both benefits and challenges associated specifically with disaster recovery for interoperability. Let’s explore them in more detail:

Benefits:

Data Accessibility and Availability: Interoperability in disaster recovery ensures that data remains accessible and available across different systems and organizations during and after a disaster. This capability enables timely decision-making, efficient coordination, and effective response efforts.

Collaboration and Coordination: Disaster recovery for interoperability promotes collaboration and coordination among various entities involved in the recovery process. It allows different organizations, such as emergency responders, to share critical information, resources, and expertise, thereby enhancing overall response effectiveness.

Rapid Information Exchange: Interoperability facilitates the rapid exchange of information between different systems and stakeholders. This enables real-time situational awareness, timely updates, and the ability to make informed decisions based on accurate and up-to-date data.

Seamless Integration: Disaster recovery efforts that prioritize interoperability ensure seamless integration between disparate systems. This integration enables smooth data flow, eliminates information silos, and enhances the overall efficiency and effectiveness of the recovery process.

Challenges:

Technical Compatibility: Achieving interoperability in disaster recovery can be challenging due to the need for technical compatibility between different systems, platforms, and protocols. Integrating legacy systems with newer technologies, addressing data format inconsistencies, and ensuring seamless communication can require significant effort and resources.

Data Standardization: In disaster recovery scenarios, different organizations often use their own data standards, formats, and terminology. Harmonizing and standardizing these diverse data elements can be complex and time-consuming. Without consistent data standards, interoperability may be compromised, leading to delays, miscommunication, and errors.

Security and Privacy Concerns: Interoperability in disaster recovery requires the secure exchange of sensitive information among multiple entities. Ensuring data confidentiality, integrity, and availability while maintaining privacy rights is a significant challenge. Robust security measures and protocols must be in place to protect against unauthorized access, data breaches, and potential misuse of information.

Governance and Policy Alignment: Coordination and governance among multiple stakeholders are crucial for effective disaster recovery interoperability. Aligning policies, procedures, and decision-making frameworks across different organizations can be complex, especially in large-scale disasters involving multiple jurisdictions and diverse stakeholders. Clear governance structures and collaborative frameworks must be established to overcome these challenges.

Conclusion

In conclusion, interoperability offers numerous benefits in times of success and during disaster recovery, including data accessibility, collaboration, rapid information exchange, and seamless integration. However, challenges such as technical compatibility, data standardization, security concerns, and governance issues need to be addressed to maximize the effectiveness of interoperability efforts in the face of disasters. Organizations and stakeholders must work together to develop robust solutions that enhance interoperability while ensuring the resilience and reliability of their recovery processes.

While challenges persist, it’s important for organizations to work together to address these issues and ensure they’re able to reap the benefits of interoperability. Community engagement, including involvement of patients, providers, health plans, and other stakeholders in the design and implementation of health technology systems can ensure they are interoperable, effective, and align with their distinct needs and preferences. As technology continues to evolve, resiliency and redundancy will become increasingly important to achieving interoperability. Organizations that prioritize interoperability will be better equipped to succeed in today’s digital world.

The future of healthcare technology systems will depend on their capacity to adapt and evolve in response to new challenges and changing conditions. This means not only being able to respond effectively to immediate crises, but also preparing for long-term changes and uncertainties. By taking a comprehensive and multifaceted approach, we can build healthcare technology systems that are robust, resilient, and redundant in a way that meets the needs of everyone in healthcare.


The Future of Healthcare Cybersecurity

Typing on computers

The experiences of 2023 have underscored the critical importance of cybersecurity in the healthcare sector. Per HIPAA Journal, “133 million records were exposed or stolen” in 2023. The recent Change Healthcare cyber incident, which is still impacting the healthcare ecosystem, indicates that 2024 could likely be another record-breaking year for healthcare cyberattacks in the U.S.

Ransomware attacks are the fastest growing threat in the U.S. The U.S. Department of Health and Human Services (HHS) and Office of Civil Rights (OCR) identified a 278% increase in cyberattacks involving ransomware from 2018-2022. To clarify, this is just the data breaches that were reported to the OCR.

The fallout from a ransomware attack is comprehensive:

  • Loss of personal health data
  • Loss of trust by patients, members, customers and partners
  • Decrease in employee productivity and morale
  • Extensive system downtime
  • Legal and regulatory fines
  • Steep financial implications, like paying the ransom and the cost to get systems back up and securely running

The alarming rise in cyber threats – namely ransomware – highlight the urgent need for enhanced cyber resiliency and robust security measures in healthcare. The healthcare sector is predicted to continue its investment in cybersecurity, focusing on resilient data management practices, threat detection, and employee training, while expanding into new technologies (like artificial intelligence) and collaborative efforts.

Here are five ways to reduce your risk and secure personal health information (PHI) from cyberattacks

1. Consistent Data Management Practices

Consistency is key, especially when it comes to basic cyber protection. These five stepping stones are just a start to laying out a consistent cybersecurity plan.

  1. Create a secure cybersecurity policy – Establish a firm security stance, then periodically review, modify and update policies and procedures in response to environmental or operational changes affecting the security of Electronic PHI.
  2. Encrypt data – Convert data to ciphertext that can only be read if decrypted
  3. Backup data – Ensure PHI data are backed up frequently, at least nightly, and stored in a HIPAA-compliant data center
  4. Update systems and software – Verify information systems are up to date with the latest security patches and diligently check programs for updates.
  5. Assess and monitor vendors Ensure that third-party vendors agree to a business associate agreement (BAA) and monitor their activities to be sure they adhere to the policies. Review vendors to ensure compliance on a consistent basis.

2. Detection

As Benjamin Franklin said: “If you fail to plan you are planning to fail.” Detecting and addressing vulnerabilities in advance of an incident is critical to ensuring a strong security posture. The investment in audits and technology improvement almost always outweigh the costs of a ransomware attack.

Implementing a threat detection strategy is critical to identifying and preventing data breaches. Healthcare institutions and security leadership, like the chief information security officer (CISO), are investing more in security infrastructure. Guidehouse’s 2024 report found 85% of respondents’ organizations planned increases to their 2024 digital and IT budgets, with cybersecurity listed as their top investment priority. This demonstrates the industry’s commitment to safeguarding patient data. 

3. Employee training

To err is human and healthcare employees are no exception. Taking a human-centric approach to organizational security can cultivate shared cybersecurity responsibility, which in turn could dramatically reduce the chances of a data breach, HIPAA violation, and the costs associated with both. Given that social engineering now represents more than 50% of incidents (per Verizon’s DBIR Report 2023), the focus on the human element is pivotal to securing your data. 

Adopting this approach can (1) increase awareness of accidental and intentional HIPAA violations, and (2) empower appropriate responses to social engineering. Ultimately staff need to make decisions and take action. However, leadership must engender the organizational identity around shared security responsibility.

Instilling the values of cyber detection and resiliency helps employees feel more invested. If they understand what’s at stake, then they can make quicker decisions and adhere to monotonous, daily security measures, like multi-factor authentication (MFA).

Employers and employees should be aware of the human elements that factor into data breaches, including:

  • Stolen credentials – Implement a strong password protocol that eliminates easy to hack passwords or the use of post-it notes with passwords on desks.
  • Phishing – Monitor email (and other technology) and train employees to recognize signs of phishing, such as unusual messages from leadership or HR, and clicking on links or attachments from unknown sources.
  • Error and Misdelivery – Ensure employees review the recipient of all of their communications so they don’t send PHI or other data to the incorrect audience.

One place to start: Conduct regular employee training.

Healthcare organizations can use a wide range of training programs and courses to keep employees up-to-speed on the latest security best practices. Updated approaches will mitigate insecure employee behaviors and tackle outstanding cybersecurity risks. 

Security leaders should continue to review vendors and software to ensure they meet all requirements (such as HIPAA regulations) to effectively evaluate and educate staff, and reduce overall risk.For small and medium sized employers who have limited resources, HHS is providing free cybersecurity training courses for their staff.

4. Artificial Intelligence (A.I.)

Like nearly every other sector, the healthcare vertical is actively exploring and investing in A.I. Specifically, how it can improve data security. In fact, 73% of CIOs said they’re increasing investments into A.I. and Machine Learning (ML) (Per Gartner, 2024 Gartner CIO and Technology Executive Survey).

A.I. solutions present vast opportunities for automation: from visualization of networks, to identifying vulnerabilities at scale, to detecting suspicious behavior. Furthermore, machine learning models and A.I.-driven security can aggregate knowledge from previous experiences (in your own system and broader ecosystems) to predict and quickly respond to abnormalities. This knowledge can accelerate cyber defense within an organization and empower health systems to take proactive, automated measures to protect its network.

Before considering A.I. or another new technology, healthcare companies should continue to focus on shoring up foundational security technologies. This includes firewalls, encryption, and MFA.

5. Collaboration

One entity cannot secure everyone. Healthcare is built on interoperability. The strength of every single bond can determine the success or failure of our ecosystem. Hospitals, payers, providers, third-party vendors, and government entities must work together to ensure our security against cyber attacks.

Collaboration between healthcare institutions is anticipated to increase. While the use of disparate systems creates barriers to collaboration, the focus on standardization and interoperability can develop a more holistic, resolute system. By sharing knowledge and resources, we can collectively strengthen our defenses against cyber threats.

The U.S. Government continues to put cybersecurity in the healthcare industry at the forefront, instituting policies in the National Cybersecurity Strategy that will address cyber threats. Learn more about the HHS and the National Cybersecurity Strategy here.

In Conclusion

Early investments in consistent practices, detection, employee education, new technologies and collaboration can ensure a strong security posture that offsets potential costs of recovery and crises of confidence caused by a data breach. The lessons learned from 2023 have made it clear that cybersecurity is not just an IT issue, but a patient safety issue. As we move into the future, it is critical that the healthcare sector continues to prioritize and invest in cybersecurity measures to safeguard patient data and ensure the seamless delivery of healthcare services.


Health and Tech Professionals Gather Once Again at the 2023 HIT Conference

Our annual Health Information Technology Conference (HIT) will return to Salt Lake on Wednesday, October 18 at the Conference Center at Gail Miller Campus, SLCC. This year, we’ll look towards the “future of healthcare interoperability” with speakers, leaders and professionals from across the healthcare and technology continuum. While we will also celebrate the fact that 2023 marks our 30th year as an innovative organization, we will keep our focus on what’s coming up in the world of healthcare and technology. Some of our most exciting topics include:

  • Artificial Intelligence in healthcare
  • Billing for today and beyond
  • Cybersecurity
  • Digital transformation in healthcare
  • Documentation burden
  • HL7 and FHIR
  • Health equity
  • Health Data Utilities (HDUs)
  • Medicare updates
  • Mental health and burn out
  • Population Health
Dr. Angela Dunn

Dr. Angela Dunn, Executive Director of the Salt Lake County Health Department, will deliver our welcome keynote address in the morning.

Joy Rios

Joy Rios, founder and host of the HIT Like a Girl podcast, will present the afternoon keynote address.

We look forward to seeing you on October 18th!