From real-world patient access to nationwide scale, eHealth Exchange continues to lead as CMS requirements evolve
From Progress to Proof: Demonstrating Individual Access
At eHealth Exchange, interoperability isn’t theoretical—it’s operational.
As part of ongoing industry collaboration with the Centers for Medicare and Medicaid Services (CMS), eHealth Exchange is working with b.well Connected Health, a digital health platform for AI-powered consumer experience, and DaVita®, a comprehensive kidney care provider, to demonstrate a real-world individual access use case, showcasing how patients can securely access their health records through a trusted consumer application. This end-to-end production demonstration was highlighted at the CMS Health Technology Ecosystem event in Washington, DC (April 9).
In this scenario, a kidney patient uses the b.well app to securely request and retrieve their medical records from a DaVita location, with eHealth Exchange serving as the trusted network intermediary through the Carequality framework.
This is more than a demonstration—it’s a proof point. For DaVita, empowering patients with seamless access to their health data is a critical component of supporting individuals managing complex, chronic conditions like end-stage kidney disease, which enables greater engagement, continuity of care, and informed decision-making. For eHealth Exchange and b.well, it shows that secure, standards-based patient access is not a future goal, it’s already happening today.
And importantly, it reflects something that sets eHealth Exchange apart:
we are not building from scratch to meet CMS-Aligned Network requirements—we are building on almost two decades of real-world trusted interoperability experience.
eHealth Exchange helped pioneer workflows to support individual access queries as mobile apps and consumer-directed healthcare began to emerge. The use case has been live for a decade sitting dormant because an IAS query currently does not require a response. Today’s work builds directly on that foundation, and we are thrilled the use case is getting prime time attention with CMS involvement.
Where the Industry Stands
As the healthcare industry works toward CMS-Aligned Network requirements, one thing is clear: this is not a “flip-the-switch” moment; it’s a journey.
To date, no network that has pledged to become a CMS-Aligned Network has fully met all minimum viable product (MVP) requirements, largely because key technical and policy definitions are still being finalized across CMS Health Tech Ecosystem (HTE) workgroups.
But progress isn’t on hold—and neither are we.
How eHealth Exchange Is Moving Forward
eHealth Exchange is actively advancing capabilities across all seven CMS-Aligned Network MVP requirements:
- Advancing Patient Matching: We are aligning our patient matching practices with CMS HTE efforts and advocating for stronger identifiers—such as Member ID—to improve accuracy, particularly for payer-related exchange. With participation from 57 regional and state HIEs, our network is uniquely positioned to scale improved matching nationwide. We believe matching can be improved if we extend beyond national networks or peer-to-peer exchanges by leveraging those HIE connections.
- Expanding Access to Complete Patient Data: Our infrastructure already supports both structured and unstructured data exchange using IHE and FHIR APIs. We are now working with participants to accelerate access to unstructured content, including scanned and faxed documents, ensuring more complete query responses.For example, our experience using FHIR APIs for non-Treatment exchange to support the FDA and NIH has proven the ability to query for both structured and non-structured data and documents. Additionally, using the IHE traditional standards and querying with various class codes can successfully return non-structured documents.
- Supporting All Core Use Cases: eHealth Exchange enables data exchange across patient, provider, and payer use cases, with tailored workflows to support each. We are also extending this work into federal agencies and public health, including bi-directional exchange initiatives with organizations such as CDC’s Immunization Gateway.
- Scaling Purpose of Use (TPO and Beyond): We currently support Treatment, Payment, and Operations (TPO) and are actively expanding capabilities for non-treatment use cases through participation in HL7 Da Vinci and Helios accelerators, as well as federal partnerships with FDA, SSA, and NIH.
- Contributing to the National Provider Directory: We maintain a robust provider directory today and are committed to sharing this data with CMS as part of the National Provider Directory initiative while also helping shape best practices based on our experience.
- Leading Audit Log Innovation: As the lead of the HTE Audit Log Workgroup, eHealth Exchange is helping define how networks provide transparency into who accessed data, when, and for what purpose—a cornerstone of trust in nationwide exchange. We are excited to enable IAS access to audit events on our network.
- Maintaining HITRUST Certification: Security remains foundational. eHealth Exchange has maintained HITRUST certification for years, reinforcing our commitment to protecting sensitive patient data.
More Than Readiness—Real-World Leadership
While CMS-Aligned Network MVP requirements continue to evolve, eHealth Exchange is not waiting for final definitions to take action.
Many of the capabilities being outlined today—patient access, multi-use case exchange, purpose of use, and audit transparency—are areas where eHealth Exchange has already delivered at scale for years.
What’s changing now is not the vision, but the alignment and acceleration of these capabilities across the broader ecosystem.
Moving Forward, Together
CMS-Aligned Network readiness is a shared industry responsibility. Achieving it will require collaboration, iteration, and a focus on practical implementation.
eHealth Exchange remains committed to:
- Advancing capabilities today—not waiting for perfection
- Collaborating across the ecosystem
- Delivering real-world interoperability that benefits patients, providers, and payers
We may not be at the finish line, but we are demonstrating what’s possible every step of the way.
