Fall 2025 Issue

New Alignment
By Elizabeth S. Goar
For The Record
Vol. 37 No. 4 P. 18

CMS Aligned Networks aim to improve interoperability for patients and their data.

One of the five categories that make up the Digital Health Ecosystem unveiled in July 2025 by CMS, CMS Aligned Networks are meant to allow different types of health data sources—including health information networks and exchanges and other health technology platforms—to align with CMS goals for interoperability.

“Aligned Networks represent a transformative commitment to putting patients first. At their core, these are health technology companies that have made a promise—a promise that you, as a patient, should have immediate access to your complete health story, whenever and wherever you need it,” says Liz Lewis, associate vice president of network management for b.well Connected Health, a FHIR-based digital health platform that was among the first to pledge to become a CMS Aligned Network.

“Think about what this means for someone managing a chronic condition, or a parent coordinating care for their child, or anyone who’s ever felt frustrated trying to get their medical records transferred between doctors,” she adds. “Aligned Networks eliminate those barriers.”

Part of a Larger Ecosystem
CMS’ Digital Health Ecosystem aligns common infrastructure with private-sector innovation across clearly defined categories. Along with CMS Aligned Networks, these categories include the following:

• EHRs and Providers, to ensure active participation by making complete, timely patient data available, including structured data, real-world clinical documentation, and encounter signals that improve care coordination;

• Payers, who join or create an Aligned Network and provide claims data to aligned networks when requested by patients, providers, and, when appropriate, other payers; and

• Patient Facing Apps, whose participation will help unlock the full potential of modern digital health by delivering immediate value to patients through real-world, high-impact tools that are secure, user-centered, and connected.

Participants in each category will voluntarily meet criteria aligned with the CMS Interoperability Framework.
For Aligned Networks, this includes the appropriate exchange of clinical and claims data and the proper response to patient, provider, and payer requests. They will self-attest to meeting these criteria and agree to be reviewed if CMS suspects they are not.

For its part, CMS plans to launch key public infrastructure, such as the National Provider Directory, enable modern identity on Medicare.gov, and expand data sharing capabilities. “Aligned Networks are really about taking action, making data exchange work the way it should have worked all along. CMS is offering a voluntary path for networks, payers, providers, and digital health partners to come together under one shared interoperability framework,” says Anita Nayak, founder and CEO of ClinDCast, a health IT consulting services firm. “Think of it like everyone finally agreeing to use the same ‘language’ for health data.”

She cites, as an example, a network adopting FHIR-based application programming interfaces (APIs), which allow it to seamlessly connect with other systems, regardless of whether those systems are EHRs, payer portals, or patient-facing apps. “By aligning, participants gain access to CMS-supported infrastructure, common data exchange standards, and national recognition as interoperability leaders. The real benefit is simple: faster data movement, fewer integration barriers, and stronger collaboration between those delivering and those receiving care,” Nayak says.

Test Bed for Innovation
Lewis shares additional benefits for both participants and patients. The latter will have true ownership of their health data, for example, the ability to access clinical records on smartphones, seamlessly share them with specialists, and review test results and how they trend over time. “Your health information travels with you, empowering you to make informed decisions about your care,” she says. “For providers and care teams, this framework enables them to see the complete picture of your health—past visits, medications, test results—so they can provide better, more coordinated care without asking you to repeat your medical history over and over.”

The health care system as a whole benefits from advancing innovation by adopting modern standards, such as FHIR APIs, creating “a connected health care ecosystem where information flows securely and efficiently, ultimately improving outcomes and experiences for everyone,” Lewis explains. “What makes this particularly exciting is that it’s a voluntary movement; companies join because they believe in patient empowerment, not because they’re forced to. That commitment to doing what’s right for patients is what will truly transform health care.”

Jonathan French, senior director of public policy and content development for HIMSS, says the Aligned Network initiative “serves as a test bed for innovation, allowing participants to explore new methods, technologies, and standards that improve information access and interoperability across the health ecosystem.”

Early adopters will likely realize benefits from helping to shape what may become the next generation of national data exchange models. French points out that CMS has also promised participants unprecedented access to Health and Human Services (HHS) federal datasets. Early adopters can also gain experience, validation, and readiness for potential policy integration down the line.

Simplified Data Exchange
App developers, French says, stand to gain the most. “Apps rely on access to patient data to provide functionality and care support for their customers. Without access to robust patient data, which app developers have stated that EHRs do not provide them, their products don’t have the full capability to deliver the functionality and support that their patients demand,” he explains.

For providers, Aligned Networks can simplify and strengthen data access across care settings. This can help clinicians ensure they have more complete, real-time information for each patient at the point of care.

“The framework also supports streamlined administrative workflows, faster benefits verification, and improved prior authorization processes,” French says. “Over time, these efficiencies can improve care coordination and administrative performance while better aligning with federal interoperability efforts.”

Nayak notes that the initiative means providers will finally have point-of-care access to a complete picture of their patients without spending hours chasing down records. For patients, it offers greater empowerment. “They can access their health data from any app, without multiple logins or portals, and truly own their information,” she says. “When both sides have the right data at the right time, care becomes more connected, coordinated, and compassionate.”

Patients should gain greater control over their health data, easier access to their complete health records, and better data sharing between their care teams, according to French. Further, the trusted apps and digital tools they use to access their health data can also offer customized, data-driven support, as well as improved tools for personalized care, chronic condition management, and preventive health engagement.

“Finally, and one of the most important benefits,” Lewis says, “is that CMS has committed to participating in data exchange with networks that meet the criteria and requirements outlined in the framework. This is an incredible opportunity for both patients and providers to have a simplified way to exchange with CMS.”

Reinventing the Wheel?
While there are clear benefits to be realized from CMS Aligned Networks, assuming they live up to expectations, questions have been raised about the nascent initiative’s duplication of efforts. Most involve the Trusted Exchange Framework and Common Agreement (TEFCA), the federal initiative to create a nationwide network for securely sharing electronic health information that went live in December 2023. Other questions touch on standards. In both cases, concern is likely unwarranted.

Aligned Networks complement, rather than duplicate, TEFCA, according to Nayak. She explains that while TEFCA sets the national policy framework for data exchange, “the CMS Interoperability Framework focuses on making that exchange actually happen at the patient, provider, and payer level. Together, they complete the picture.”

Lewis goes deeper, noting that while TEFCA has focused primarily on helping doctors and hospitals share information for clinical purposes, Aligned Networks address specific barriers that have kept patients from easily accessing their own health data.

Other differences include the involvement of health plans and Interoperability Framework workflows, which are intended to support coordinated care and patient empowerment. Additionally, Aligned Network participants must be on FHIR, with a minimum of United States Core Data for Interoperability (USCDI) v3, to contribute FHIR endpoints to CMS’s planned National Provider Directory.

“Health care data sharing has been evolving for decades,” Lewis says. “CMS Aligned Networks don’t replace existing efforts like TEFCA. They expand on them with one critical difference: You, the patient, are at the center.”

From HIMSS’s perspective, TEFCA will provide formal governance structures to test the CMS Interoperability Framework ecosystem and help determine HHS’s ideal future state for nationwide exchange. However, there is no guarantee that TEFCA will be the foundational data exchange principle moving forward, according to French.

Meanwhile, Aligned Networks focus on operational behaviors and functions, such as identity management, data discovery, request/response processes, and transparent endpoint publication, across multiple types of networks. “Some organizations will engage in both efforts: using TEFCA for trusted nationwide connectivity and leveraging the CMS Framework to enable just-in-time, app-ready data exchange and innovation at the edge,” French says.

Regarding standards, he notes that Aligned Network and participant requirements build on current standards but add new requirements, such as patient identity management, data discovery, and enhanced transparency. Thus, “like TEFCA, while we expect current standards and evolving future iterations of those standards will be tested and will likely be the bedrock of this future state, certain aspects of the framework structure imply a possible policy shift in the future,” French says. “Rather than creating an entirely new set of standards, the goal is to iterate what already exists into a cohesive implementation framework. This approach accelerates real-world adoption while reducing fragmentation across programs and systems.”

Nayak concurs that the CMS initiative is not reinventing the wheel. Instead, “it’s connecting the wheels already turning. The framework builds on FHIR, HL7, and USCDI v3 but brings them under one operational playbook so everyone can move faster with consistency and confidence.”

Emphasis on Collaboration
Another question that’s been frequently raised since CMS announced its Digital Health Ecosystem is whether the technical lift or required resources would eliminate smaller networks and provider organizations from participation. The answer? Maybe. At least at first.

According to Lewis, while there is nothing in the CMS Interoperability Framework that’s new from a technology standpoint, its technical requirements do highlight the importance of bringing to the forefront specific requirements that are optional or absent from other frameworks. Thus, the technical lift won’t be as challenging as the financial and resource lift for networks.

For provider participation, “the honest answer is that the same resource challenges facing smaller and rural health systems today may persist in the early stages of CMS Aligned Networks,” she says. “However, there’s an important distinction to understand about who faces the biggest barriers. The primary factor isn’t necessarily the size or location of a health care organization: it’s whether they use Certified EHR Technology.”

Any provider using certified systems is already required to have the necessary FHIR APIs in place, Lewis explains. But smaller providers who haven’t adopted certified technology and those that typically serve rural communities “play vital roles in patient care but have historically faced higher barriers to implementing interoperability solutions.”

Lewis adds, “If you live in a rural area or receive care from smaller community providers, you might initially experience gaps in having all your health information connected. The concern is real. Patients shouldn’t be disadvantaged simply because their local hospital or pharmacy lacks the resources of larger health systems. Providers that are not easily connected can utilize technology vendors.”

Nayak points out that CMS has been “very intentional about keeping this inclusive” and that rural and community-based systems can participate via cloud-based tools and low-cost FHIR connections. “It’s about collaboration, not competition,” she says. “The shared infrastructure makes it achievable for everyone.”

French, meanwhile, suggests it’s too early to tell whether resource-challenged provider organizations will be shut out. More detail is needed to fully define the technical and operational requirements, “but participation to date has been encouraging. All the currently recognized Qualified Health Information Networks, as well as 12 organizations representing health data utilities, state health departments, information exchanges, and EHR vendors, have signed on as pledges. This suggests the lift is manageable with existing infrastructure.”

He adds, “Ultimately, equitable participation is critical. HIMSS advocates for inclusive interoperability and encourages CMS and partners to provide technical assistance and incentives to ensure smaller, rural, and resource-limited organizations can engage meaningfully and benefit.”

Forward Momentum
While it is still too soon to tell whether CMS Aligned Networks will achieve their intended purpose of bringing health data sources together to align with the agency’s interoperability goals, the signs are encouraging. “CMS Aligned Networks represent an important step toward an open, connected health ecosystem,” French says. “HIMSS views this as an opportunity to accelerate adoption of trusted, standards-based exchange; test and refine scalable models for data access and identity; and ensure all communities benefit from interoperability progress.”

If the voluntary initiative is successful, it could ultimately eliminate the need for future mandates to accomplish the same objectives, Nayak adds. “The goal is to show that we can achieve real interoperability through innovation and shared effort, not by adding more rules,” she says, noting that “those who lead early will be best prepared if alignment later ties to reimbursement. It’s about acting today to stay ahead of tomorrow.”

— Elizabeth S. Goar is a freelance health care writer based in Benton, Wisconsin.