The Interoperability Mandate and the Next Chapter for Health IT
The ONC's final rule on information blocking and FHIR-based interoperability APIs created a new floor for health data portability in 2021. Eighteen months later, the effects are becoming visible in how health IT companies architect their platforms and how payers and providers think about vendor relationships.
The most significant early effect is on the EHR integration market. For two decades, EHR vendors — particularly Epic and Oracle Health — competed in part on integration complexity: the more difficult it was to connect a third-party application to their system, the stronger the switching cost for the health system and the harder it was for new entrants to compete. The interoperability mandate does not eliminate this advantage, but it reduces it in a measurable way. FHIR R4 APIs are now legally required to be accessible to authorized applications, which means the first integration hurdle for a clinical AI company is lower than it was in 2019.
The second effect is on contracting. Health systems that previously signed exclusivity arrangements with EHR vendors that effectively blocked third-party clinical application access are now reviewing whether those arrangements are permissible under the information blocking rules. Several large health systems have publicly acknowledged that their vendor contracts needed revision to comply. This is creating contract renegotiation cycles that are opening doors for new clinical AI vendors that were previously closed.
The investment implication: companies building clinical AI that depends on longitudinal patient data access should now be evaluating their FHIR architecture as a primary competitive variable, not a technical implementation detail. Companies that have built robust FHIR-based integration layers — that can access patient data across multiple EHR systems through standardized APIs rather than custom integrations — have a structural advantage in scaling their deployments and in competing for health system contracts where interoperability compliance is an explicit procurement requirement.