Healthcare interoperability has been "almost there" for as long as anyone can remember. But 2025 was arguably the year things actually shifted, and 2026 is shaping up to be when the effects become undeniable.

Here's an honest assessment of where things stand, who's winning, and what's coming next.

Where We Actually Are

Patient access APIs are real and working. The ONC g(10) APIs mandated by the Cures Act are live across all major EHR systems. Patients can authorize third-party applications to access their health data. Millions of API calls happen daily. This isn't vaporware or pilot programs; it's production infrastructure being used at scale.

TEFCA is operational but early. The Trusted Exchange Framework and Common Agreement launched for production exchange in late 2024. QHINs are connected, transactions are flowing, but volumes are still ramping. The network effects that will make TEFCA genuinely valuable are still building. It's real, but not yet transformative.

Information blocking enforcement has teeth. OIG has moved from guidance to action. Complaints are being investigated, organizations are adjusting behavior, and the threat of enforcement is no longer theoretical.

FHIR is the de facto standard. The debate about FHIR versus alternatives is over; FHIR won. The question is no longer whether healthcare will adopt it, but how quickly implementations will mature.

Winners and Losers

Winners:

Patient-facing health applications. The Cures Act created a real pathway for apps to access patient data with patient authorization. Companies that built for this model have genuine data access and a durable regulatory foundation under them.

EHR-agnostic infrastructure providers. Companies that abstracted away EHR complexity and offered unified APIs found strong demand from builders who didn't want to manage direct integrations.

Health systems that embraced openness. Organizations that leaned into API access rather than resisting it are seeing returns in patient engagement and partner ecosystem development.

Losers:

Legacy HIE business models. Traditional health information exchanges built on provider-to-provider sharing are being squeezed from two directions; patient-directed access provides an alternative pathway, and TEFCA creates a national option.

Organizations that bet against the Cures Act. Some entities assumed enforcement would be weak or the rules would eventually be rolled back. That hasn't happened.

Proprietary data lock-in strategies. The economics of trapping data inside closed systems are weakening. Patients and partners increasingly have alternatives.

The HTI-5 Shift

The December 2025 HTI-5 proposed rule is the most significant policy development in this space in years. A few things worth paying attention to:

Over 50% of ONC certification criteria are proposed for removal, resetting the certification program around FHIR APIs and AI-enabled interoperability and clearing away legacy requirements that had accumulated over decades.

AI is explicitly addressed for the first time. The rule updates definitions to allow "autonomous AI to retrieve and share health data" - the first federal rule-making to directly contemplate AI applications accessing patient data.

Information blocking exceptions are being tightened, specifically targeting the gap between technical compliance and practical obstruction.

The TEFCA Manner Exception is proposed for removal, signaling that TEFCA participation may shift from optional to expected.

If HTI-5 is finalized as proposed, it accelerates everything already underway. FHIR becomes more central. AI applications get clearer regulatory pathways. Strategies built around obstruction become harder to sustain.

What's Coming Next

AI-healthcare integration will accelerate. HTI-5's explicit recognition of AI data access, combined with the explosion of AI health applications, creates real momentum. Expect more AI tools requesting patient data access and more infrastructure built to support them.

Patient expectations will rise. As more applications offer patient-directed data access, patients will come to expect it. Organizations that make access difficult will face both competitive pressure and patient dissatisfaction.

FHIR implementation quality will improve. Early implementations often did the minimum required. As usage scales and enforcement continues, EHR vendors will be pushed to improve; better documentation, more consistent behavior, broader resource coverage.

Infrastructure consolidation will follow. Building and maintaining EHR integrations is expensive. Companies that don't want that burden will increasingly rely on infrastructure providers. As the market matures, expect consolidation.

New use cases will emerge that we haven't anticipated. With data access infrastructure in place, applications nobody has built yet will become possible. The same way mobile app stores enabled software their creators didn't foresee, health data APIs will enable unexpected innovation.

The Strategic Imperative

The interoperability landscape in 2026 requires clear positioning depending on where you sit.

For health systems, API access is a feature, not a threat. Data liquidity is a competitive advantage. Build for it.

For EHR vendors, the era of minimum viable compliance is ending. Organizations will increasingly choose systems with better developer experience and API quality.

For health tech companies, the regulatory and market momentum behind patient-directed access is clear. Build for it and don't bet against it.

For healthcare AI, HTI-5 is a greenlight. The applications with access to comprehensive clinical data will outcompete those without it.

Where We Stand

We built Consolidate Health for this landscape; patient-directed data access infrastructure before HTI-5 made it explicitly AI-friendly, EHR integrations before the market demanded them. The bet that patient-authorized access would define the future of healthcare data is paying off.

The interoperability landscape in 2026 is no longer a debate about whether data will flow. It's about who builds the best infrastructure to move it.