CMS Interoperability final ruling and why it matters

Our thoughts on the recently announced Final Interoperability Ruling

March 10, 2020

CMS recently released its final ruling on interoperability, or to give it it’s more formal title, The Interoperability and Patient Access final rule: CMS-9115-F. The fundamental objective of the ruling is to give the public access to their own healthcare data so they can make better healthcare decisions.  

The HIPAA Privacy Rule of course already gave people the right to see and receive copies of the information in their medical and other health records but this new ruling will make sure that data is available in a secure, standards-based way. It wasn’t unheard of for people to get a CD with screenshots of their data. The new ruling makes sure that patients will be able to use smartphone apps to get access to their data. 

Due to the wide variety of formats and varying degrees of openness of medical data, it’s made it hard to easily integrate data into patient-facing applications. If patients can’t access their data in a useful way then that impacts how they see their health and has knock on effects on their healthcare decision making. This ruling puts patients front and center and will hopefully lead onto some better health outcomes.  

CMS-9115-F mandates that CMS payers and providers have an open a legal, enforceable right to see and receive copies upon request of the information in their medical and other health records  API (Application Programming Iinterface) to allow anyone to access medical data in a standardized format (HL7 FHIR Release 4.0.1). The API will allow patients to easily access their claims and encounter information, including costs, as well as a defined subset of clinical information 

Patients aren’t the only ones who benefit! By building this standard, CMS is also facilitating the easy exchange of data between payers and providers and various stakeholders within the healthcare system. Maybe your nephrologist will be automatically notified if you are admitted into an Emergency Room or miss an appointment with your nutritionist.  

From this post you may think everyone in the healthcare industry is rejoicing for interoperability (at a safe distance). In reality, there are mixed feelings on the matter. Companies wanting to use the data in their products or build new products with the data are pleased and companies that benefit from keeping the data siloed to sell their own proprietary products are not. Concerns raised against the ruling revolve mostly around data privacy and timing. Overall, the sense is that interoperability is a necessary foundation for a functioning healthcare system. The disagreement is around how and when. 

While there is still much left to be determined, we at pulseData believe this ruling will give patients more control of their data and pave the way for payers and providers to deliver better care for their patients. Please get in touch with us at if you have comments or questions about this post.