On July 31, 2025, the Centers for Medicare & Medicaid Services (CMS) published its new Interoperability Framework, part of the broader digital health ecosystem initiative. While voluntary, the framework sets a high bar. CMS set the bar at HITRUST-level assurance — requiring validation equivalent to HITRUST certification. The message is clear. Secure health data exchange requires more than intent. It requires demonstrable trust. 

Why HITRUST Matters 

Some may view HITRUST as just another compliance checkbox. It is far more. HITRUST is widely accepted and has become the gold standard for safeguarding healthcare data by combining prescriptive controls, a rigorous assessment process, and consistent certification. Its inclusion in the CMS framework accomplishes three things: 

• Affirms credibility and commitment: Certification signals that networks prioritize actionable, defensible security — not just policies on paper. Patients, providers, and regulators alike gain confidence that systems are truly hardened. 

• Enables a shared standard: With many healthcare organizations already aligned to HITRUST, it provides a common language for risk and security. That alignment lowers friction for interoperability networks trying to collaborate. 

• Elevates trust: By embedding HITRUST, CMS ensures that networks build not only technical connections but also trusted ones. 

It’s also important to note that HITRUST doesn’t replace HIPAA compliance. Rather, it offers a structured, auditable path to achieving and proving the safeguards the HIPAA Security Rule requires. 

HITRUST as a HIPAA Compliance Accelerator 

For organizations adopting the CMS Interoperability Framework, HITRUST offers a dual benefit: satisfying CMS requirements while accelerating HIPAA compliance. Here’s how the alignment plays out: 

• Administrative, physical, and technical safeguards: HIPAA requires covered entities and business associates to protect electronic protected health information (ePHI). HITRUST maps directly to these safeguards, offering detailed, actionable guidance across all three categories. 

• Risk analysis and management: A cornerstone of HIPAA, risk assessments and ongoing risk management are also embedded in the HITRUST certification process. This overlap reduces duplication and ensures discipline. 

• Audit trails and documentation: CMS requires verifiable logs and authentication records. HITRUST similarly emphasizes documentation, monitoring, and continuous updates — ensuring compliance efforts reinforce one another. 

The result? Organizations meet CMS expectations while simultaneously advancing HIPAA obligations. Instead of running two parallel compliance efforts, HITRUST helps consolidate and streamline. 

Building a Modern, Secure Health Data Exchange 

The CMS Interoperability Framework is about more than security. It lays a foundation for a patient-centered, digitally connected ecosystem. Key features include: 

• Patient-directed access: Individuals gain greater control over how their health data moves between systems. 

• FHIR API-based exchange: Modern, standards-driven APIs replace older, fragmented methods of data transfer. 

• Strong identity and trust protocols: HITRUST (or equivalent validation) underpins identity management, authentication, and data security. 

• Secure credentials and consent enforcement: Transparent consent processes, verifiable audit logs, and credentialing requirements ensure accountability. 

CMS has also partnered with more than 60 private-sector organizations spanning health information networks, EHR vendors, payers, and digital platforms to become CMS-Aligned Networks by early 2026. This momentum underscores the initiative’s transformational potential. 

Final Thoughts 

The CMS Interoperability Framework marks a significant step toward a healthcare system where data flows securely, patients are empowered, and trust is embedded by design. Its requirement for HITRUST certification is not a box-checking exercise but rather recognition that shared, high-assurance standards are essential to safe interoperability. 

For organizations, the benefits are clear. HITRUST helps streamline HIPAA compliance, reduces redundant audits, and demonstrates maturity in risk management. For the broader system, it builds resilience, fosters collaboration, and strengthens the foundation of trust patients expect. 

As CMS advances its digital health ecosystem, stakeholders that align early will not only meet requirements, but they will shape a connected, secure, and trusted future of healthcare.