Interoperability Is Not a Technology Problem: You're Already Late

Everyone tells you to wait for the perfect FHIR endpoint. They say, "hold off until USCDI v4 is finalized" or "let TEFCA mature." That's backwards. You're already late. The real barrier to interoperability isn't the technology—it's your own passivity. You don't need another standards committee; you need to start shipping data today, using the tools you already have.

You Can't Afford to Wait for the Future Standard

Imagine you're the informatics director at a mid-sized community hospital. Your physicians are complaining they can't see records from the neighboring health system. Your board just read about TEFCA and asks why you're not connected yet. But your legacy systems still speak HL7 v2, and your developers are itching to build on FHIR. The instinct is to stall until "true" interoperability arrives. That's a mistake.

Consider the numbers. Since 2011, EHR adoption in U.S. hospitals jumped from 28 percent to 96 percent by 2021 (ONC / HHS Report to Congress). Yet, everyone still struggles to share data across organizations. Why? Because adoption of certified EHRs—which now covers 96 percent of hospitals and 78 percent of office-based physicians—didn't solve the exchange problem. It just gave you more silos.

Meanwhile, HL7 v2—a standard first published in 1987—is still used by over 95 percent of U.S. healthcare organizations (HL7 V2 Product Brief). That's the real backbone of today's data exchange. You can't ignore it while chasing the shiny FHIR object. The pragmatic path is to use what's already in place to move data now.

Map the Data You Already Have

Start by taking stock of the data elements you're already collecting. The U.S. Core Data for Interoperability (USCDI) version 3, released in 2022, expanded to 94 data elements across 19 classes (ONC Standards Bulletin 2022-2). That's your roadmap for what should be flowing. Most of those elements—patient demographics, medications, problems—are sitting in your systems. They're not locked in a vault; they're just not being formatted for exchange.

So, pick one high-value use case. Maybe it's the emergency department handoff. Your physicians need to see the last discharge summary, the problem list, and recent meds. That's a typical HL7 CDA document—a discharge summary or a pathology report (HL7 CDA Product Brief). You can generate those today, without waiting for a new FHIR server.

Don't Let Security Fears Stall You

Now, you're thinking: but HIPAA. You've read the penalty schedule—$73,011 per violation for willful neglect corrected in 30 days, up to $2,190,294 per year (Federal Register 2026 HIPAA CMP Adjustment). That makes you want to freeze. But HIPAA doesn't require perfection; it requires reasonable safeguards. The Security Rule asks for administrative, physical, and technical safeguards that are appropriate to your size and complexity (eCFR 45 CFR Part 164 Subpart C).

NIST SP 800-66 Rev. 2, published in February 2024, gives you a practical guide to implementing those security measures (NIST SP 800-66 Rev. 2). You don't need to build a fortress; you need to encrypt data in transit, use unique user IDs, and have an emergency access procedure. Those are all addressable or required implementation specifications under the Security Rule's Access Control standard (eCFR 45 CFR Part 164 Subpart C).

And remember, HIPAA actually permits sharing for treatment without authorization. The Privacy Rule's minimum necessary standard applies to routine uses, but treatment disclosures are allowed. You can share data with the next provider without waiting for a signed release (eCFR 45 CFR Part 164 Subpart E).

Follow the Money—and the Penalties

Interoperability isn't just a nice-to-have; it's now tied to reimbursement. The MIPS Promoting Interoperability category is worth 25 percent of your MIPS score for the 2026 performance period, with a performance threshold of 75 points (Federal Register CY 2026 Physician Fee Schedule). If you don't meet the threshold, you face a negative 9 percent payment adjustment. That's real money.

Also, the information blocking rule, under the 21st Century Cures Act, makes it illegal to interfere with the access, exchange, or use of electronic health information unless covered by an exception (ONC / HHS Information Blocking). The law applies to providers, health IT developers, and HIEs (ONC / HHS Information Blocking). So, refusing to share data isn't just bad practice—it's a legal liability.

Start with One Connection, Then Scale

Here's your concrete plan. Pick one partner—maybe the skilled nursing facility you send the most patients to. Establish a direct, secure exchange using your existing HL7 v2 interface. If you don't have a direct connection, use a health information exchange (HIE) or a vendor that supports TEFCA. TEFCA is live: the first Qualified Health Information Networks (QHINs) were designated in December 2023, and data is flowing (ONC / HHS TEFCA). You can join a QHIN and exchange data nationwide.

But don't wait for the perfect technical setup. Start by sending a CCD (Continuity of Care Document) for every discharge. Use the data elements in USCDI. You'll find that most of the information is already in your EHR; you just need to enable the export.

As you get comfortable, you can layer on FHIR for patient-facing APIs. The CMS Patient Access API, required since January 2021, already mandates FHIR R4 for payers (Federal Register CMS Interoperability and Patient Access Final Rule). Your hospital may not be a payer, but your patients will soon expect to pull their data into third-party apps. Build that API now.

Takeaway

Stop waiting for a future that's already here. The tools you need—HL7 v2, CDA, FHIR, TEFCA—are available today. You have the data, you have the standards, and you have the regulatory push. The only thing missing is your decision to start. Choose one partner, one use case, and one data class. Exchange one record successfully, and you'll prove to yourself that interoperability is possible. Then, scale.

Sources

• ONC / HHS (Report to Congress) - https://healthit.gov/news/onc-outlines-health-it-interoperability-progress-report-congress/
• HL7 V2 Product Brief - https://www.hl7.org/implement/standards/product_brief.cfm?product_id=185
• ONC Standards Bulletin 2022-2 (USCDI v3) - https://healthit.gov/standards-onc-technology/onc-standards-bulletin/onc-standards-bulletin-2022-2/
• Federal Register (2026 HIPAA CMP Adjustment) - https://www.federalregister.gov/documents/2026/01/28/2026-01688/annual-civil-monetary-penalties-inflation-adjustment
• Federal Register (CY 2026 Physician Fee Schedule) - https://www.federalregister.gov/documents/2025/11/05/2025-19787
• ONC / HHS (TEFCA) - https://www.healthit.gov/topic/interoperability/policy/trusted-exchange-framework-and-common-agreement-tefca