Identify the last 10 attributed patients known to have been discharged from a local hospital, using the practice's ADT feed, HIE alerts, payer transition file or chart review. For each one, answer five questions. Did an alert reach the practice? If so, who received it? Who opened it? Was medication reconciliation completed? Was follow-up scheduled within the practice's applicable transition-of-care standard, payer measure or clinical protocol?

This exercise often reveals that a notification arrived but no reliable action followed.

Connection does not create capability

HIMSS describes interoperability as the ability of systems, devices and applications to access, exchange, integrate and cooperatively use data in a coordinated way,¹ and what matters most in the above scenario is cooperatively use.

A practice can operate an EHR, a patient portal, a telehealth platform, lab interfaces, an HIE connection and payer portal access and still fail to get the right information in front of the right person while it still matters. A hospital summary filed in an unmonitored folder has arrived. It has not supported care. A care-gap file uploaded by a payer helps no one until someone reconciles attribution, validates whether the gap is real and assigns outreach. A reading from a patient's remote monitoring device creates value only once thresholds, review responsibility and a response pathway exist.

Standards make exchange possible. HL7 FHIR supports much of modern API-based exchange,² and USCDI defines standardized data classes and elements for interoperable exchange.³ Structured, standardized data are easier to reconcile, report and reuse than scanned documents and free text. A fax converted to a PDF and scanned into the chart may move information without making it searchable, computable or usable in downstream workflows.

Exchange failures reveal ownership gaps

Sort the failures your practice experiences and a pattern will quickly appear.

Few of these failures are purely technical. Each also exposes an ownership, routing or exception-management gap.

Four governance questions cover most of them.

1. Patient matching — who resolves duplicates, overlays and unmatched outside records?
2. Source of truth — which system controls demographics, insurance, the medication list, the problem list, the attributed panel, referral status and care-gap closure? Outside information can inform the record; it usually needs review before it becomes authoritative.
3. Routing and reconciliation — does incoming information land in a monitored queue where someone decides whether it needs clinician review, medication reconciliation, referral closure, outreach, billing action or correction?
4. Monitoring — is exchange performance measured at all?

You don't need many measures — just a few that show whether the pipes are working and nothing is piling up unseen. A practical set: how often interfaces fail; how many results never matched to a patient; how long it takes to reach a patient after a discharge alert; what share of referrals actually close; how quickly portal messages get answered; how long patient record requests take, and how many are finished within the deadline; and how many payer-file discrepancies are still open.

Before you join another network

Health information exchange improves care when outside information shows up at a moment a decision is being made. AHRQ notes that exchange can improve quality and efficiency, partly because clinicians make better-informed decisions and partly through reduced duplicate testing.⁴

The value depends on four things the vendor cannot promise: participation, timeliness, completeness and routing. If the hospitals, specialists and labs your patients use do not contribute useful data, the connection is decorative. If the alert lands after the relevant clinical window, it missed the opportunity. If documents arrive as an unfiltered stream with no owner, the connection added work.

TEFCA provides a nationwide network-of-networks for HIE. ASTP/ONC sets overall policy; the Recognized Coordinating Entity develops and maintains the Common Agreement, manages QHIN designation and monitors designated QHINs.⁵ National-scale exchange does not change the local work. Retrieved data still has to be routed, reviewed and reconciled by someone in the medical group.

Consent adds a further layer. Exchange networks operate under different consent models depending on state law, network rules and data category. Staff need to know how preferences are recorded, how they affect exchange, and who reviews questions touching sensitive categories rather than improvising an answer at the front desk. Practices that create or receive records protected by 42 C.F.R. Part 2 should also verify that consent, notice, redisclosure and complaint workflows reflect the requirements that became applicable Feb. 16, 2026.⁶

Don’t forget the portal

Patient access is the most visible interoperability a practice has, and the place where good intentions can easily result in operational strain.

Running a patient portal well means making seven decisions up front: how you confirm a patient is who they say they are when they sign up; how you give access to caregivers, parents, guardians and other authorized representatives; which test results post automatically, and what plain-language explanation goes with them; where each kind of message goes — front desk, clinical, refills or billing; how fast the practice promises to respond; how patients are told the portal is not for emergencies; and what options are left for patients who can't or won't use it.

That last one matters more than it usually gets credit for. A practice can improve access for patients comfortable with apps while worsening it for patients without broadband, devices, language support, disability accommodations or proxy help. Review portal activation and message use by age, language, payer and site. Where activation is low, investigate the barrier before assuming disinterest — the fix is often enrollment support or translated instructions rather than a new feature.

Payers are about to send practices more data than before. Under CMS-0057-F, affected health plans must build standardized digital connections (APIs) for provider access, plan-to-plan data sharing and prior authorization. Some pieces took effect in 2026; the provider-access, plan-to-plan and prior-authorization connections generally start Jan. 1, 2027.⁷ But more data arriving does not, on its own, lighten anyone's workload. Practices can use the lead time now to decide who will review incoming information — attribution files, prior authorization responses and the rest — and what happens to it once it arrives.

Manage information-blocking risk through operations

Information-blocking risk should be managed through operating workflows, not left solely to legal review.

ASTP/ONC describes information blocking as a practice by an actor likely to interfere with access, exchange or use of electronic health information, except where required by law or covered by an exception. For healthcare providers, the standard also asks whether the provider knew the practice was unreasonable and likely to interfere. A practice that does not meet an exception is not automatically information blocking; the facts are evaluated case by case.⁸

Operational warning signs include requiring in-person pickup when feasible electronic delivery is available, letting access requests drift beyond required timelines, charging improper fees, declining a valid electronic-delivery request without examining the applicable access or authorization pathway, or keeping exchange dependent on a manual workaround nobody can explain.

For each restriction, a practice leader can ask one question: can we explain it through privacy, security, infeasibility, another recognized exception, or a requirement of law? A restriction that survives only out of habit needs a second look.

Manage it as daily work

Keep a live list of active interfaces, APIs, HIE connections, payer portals and exchange relationships. Give each pathway a business owner and a technical owner — two names, because the person who knows the workflow is rarely the person who can fix the connection. Monitor failures and unmatched records. Reconcile payer files and external results against local records. Test exchange workflows after upgrades or vendor changes. Include exchange dependencies in downtime planning, since an outage in a pathway you forgot you had is still an outage.

Repeat the discharge test and track whether alert receipt, outreach, medication reconciliation and follow-up improve.

Additional reading from MGMA

• “A New Era of Clinical Information Exchange: What Practice Leaders Need to Know About TEFCA and QHINs” (MGMA podcast)
• “Information Blocking Toolkit for Medical Groups” (Federal Policy Resource)

Notes

1. HIMSS. "Interoperability in Healthcare." https://www.himss.org/resources/interoperability-healthcare
2. Health Level Seven International, "FHIR Overview." https://hl7.org/fhir/overview.html
3. Assistant Secretary for Technology Policy / Office of the National Coordinator for Health Information Technology, "United States Core Data for Interoperability." https://www.healthit.gov/isp/united-states-core-data-interoperability-uscdi
4. Agency for Healthcare Research and Quality, "Health Information Exchange." https://digital.ahrq.gov/health-it-tools-and-resources/evaluation-resources/health-information-exchange
5. Assistant Secretary for Technology Policy / Office of the National Coordinator for Health Information Technology, "Trusted Exchange Framework and Common Agreement (TEFCA)." https://healthit.gov/policy/tefca/
6. U.S. Department of Health and Human Services, "Fact Sheet: 42 C.F.R. Part 2 Final Rule." https://www.hhs.gov/hipaa/for-professionals/regulatory-initiatives/fact-sheet-42-cfr-part-2-final-rule/index.html
7. Centers for Medicare & Medicaid Services, "CMS Interoperability and Prior Authorization Final Rule (CMS-0057-F)." https://www.cms.gov/initiatives/burden-reduction/overview/interoperability/policies-regulations/cms-interoperability-prior-authorization-final-rule-cms-0057-f
8. Assistant Secretary for Technology Policy / Office of the National Coordinator for Health Information Technology, "Information Blocking." https://healthit.gov/information-blocking/