I recently finalized our last Interoperability Outlook report of the year for subscribers, and it gave me a moment to step back and reflect on what I’ve observed after producing these quarterly reports throughout the past year in my role as Regulatory Resource Center Lead at POCP.
What stands out most is not any single regulation or policy shift, but a broader change in how this Administration appears to be influencing interoperability and health IT more broadly. The approach looks materially different from what we’ve seen historically, including during the first Trump administration.
A Shift Toward Voluntary, Market-Driven Collaboration
One of the most notable trends is the Administration’s increased reliance on voluntary public-private partnerships to drive progress. A prime example is the CMS Pledge program, which is focused on catalyzing action through industry commitment rather than formal rulemaking alone.
That strategy moved from vision to execution at the CMS Health Tech Ecosystem Connectathon, hosted by the Centers for Medicare & Medicaid Services in November and its December 9th meeting with Clear. The Connectathon was designed to allow organizations across pledge categories to demonstrate progress toward their commitments, highlighting real-world functionality and active collaborations. Participants also broke into hands-on workshops to surface practical challenges and barriers, with formal workgroups established to continue this work into 2026. CMS announced its first official contract with a public company, CLEAR, to modernize identity verification for Medicare beneficiaries and providers on Medicare.gov. In early 2026, Medicare.gov will integrate CLEAR1 — CLEAR’s secure identity platform — for account creation, account recovery, and access to healthcare information.
While these initiatives are voluntary, they are not passive. In addition to events like the Connectathon and the CLEAR announcement, work group meetings are taking place both in Washington, DC, and through shared digital collaboration spaces. While the cadence of these meetings is formally defined, there is clear evidence of ongoing engagement and coordination across stakeholders.
Altogether, this reflects a meaningful pivot toward sparking innovation through collaboration, with government increasingly acting as a convener and facilitator rather than relying solely on prescriptive regulation.
Regulatory Uncertainty and the Impact of the Government Shutdown
At the same time, the recent government shutdown has introduced uncertainty into the traditional regulatory timeline. As of now, no formal Fall Unified Agenda of Regulatory and Deregulatory Actions has been released, which is notable given that it would typically be available by this point in the year.
This delay makes it more difficult for stakeholders to confidently plan for near-term policy direction, particularly for organizations that depend on federal rules to guide strategic investment and implementation timelines.
Signals Pointing Toward Regulatory Rollbacks and AI Policy Tension
The Administration also openly signaled interest in rolling back certain regulations. A leaked draft executive order, later signed on December 13th, “Ensuring a National Policy Framework for Artificial Intelligence,” aims to limit states’ ability to regulate artificial intelligence. We expect the states to continue introducing AI legislation, as the Executive Order lacks legal authority over them.
It underscores the growing divide between a federal posture that favors minimal new AI regulation in healthcare and market-led innovation, and the more risk-averse stance emerging from states and industry stakeholders seeking guardrails to prevent unintended harm and constrain bad actors.
As a result, stakeholders should be paying close attention not only to federal activity, but also to:
- State-level legislation introduced in 2026
- Pharmacy board rules and guidance
- State Medicaid and Medicare policy direction
For organizations operating across multiple states, this layered regulatory environment is becoming increasingly complex.
States Will Continue to Act, With or Without Federal Leadership
This new federal approach, however, does not change a long-standing reality in healthcare policy: states will act when the federal government is slow to move, and even when federal policy is active, states often add their own overlay of laws, rules, and clarifications to tailor requirements to local needs.
This dynamic will remain especially relevant for interoperability, pharmacy regulation, and emerging AI policy in healthcare.
What This Means for Stakeholders
Keeping pace with this mix of activities is challenging. Interoperability today is shaped by so many factors, including federal rules and legislation, standards development, multi-stakeholder initiatives, and an increasingly active state policy environment.
If staying on top of this landscape is a struggle, Interoperability Outlook, our quarterly report delivered to subscribers, may be helpful. Each edition synthesizes key federal interoperability developments, standards activity, and multi-stakeholder initiatives shaping the market.
In parallel, POCP also offers subscription services focused on Federal key trends and tracking state-level laws and rules, for e-prescribing, electronic prior authorization, long-term post-acute care, and other specialty regulatory domains. These services are delivered through an easy-to-use online portal that centralizes:
- State legislation
- Pharmacy board rules and guidance
- Medicaid and Medicare policy updates
Our team sifts through hundreds of proposed and enacted policies and guidance documents each quarter to curate what is truly relevant for subscribers, along with notable changes. Each subscription also includes three hours of consulting time per quarter to ask questions, validate assumptions, and gain clarity on how these policies may affect your organization.
We are also actively exploring a new service focused specifically on tracking state-level AI in healthcare legislation and rulemaking. If AI policy is a concern for your organization, we would welcome your perspective as we shape this offering.
If you would like to learn more about any of these services or share what your organization needs related to interoperability or AI policy tracking, please reach out to me with your questions, input, or to schedule a chat.
