Health and Human Services agencies at federal, state, and local levels are under increasing pressure to share data effectively across program boundaries. The vision is compelling: integrated services that see the whole person rather than fragmented interactions across siloed programs. The reality of achieving interoperability, however, involves navigating complex standards landscapes, shifting funding mechanisms, and evolving enforcement priorities.
The Push Toward Integration
The rationale for HHS interoperability is clear. A family receiving SNAP benefits, Medicaid, and childcare assistance shouldn't need to provide the same information three times to three different agencies. Case workers should be able to see a complete picture of the services a client is receiving. Outcomes should be measurable across programs, not just within them.
Federal guidance increasingly emphasizes these goals. CMS, ACF, and other HHS agencies have released interoperability frameworks, encouraged adoption of modern standards, and tied funding to measurable progress on data sharing capabilities.
The Standards Landscape
Healthcare has converged around FHIR (Fast Healthcare Interoperability Resources) as the dominant standard for modern system integration. HHS programs are following this lead, with FHIR-based specifications emerging for human services data exchange.
Key standards to track include:
- NIEM (National Information Exchange Model): Provides data definitions for information sharing across justice, emergency management, and social services domains.
- FHIR Human Services profiles: Extend the healthcare FHIR standard to cover social determinants and human services information.
- MiHIN and other state HIE models: Health Information Exchanges that are expanding scope to include social services data.
- MITA (Medicaid Information Technology Architecture): CMS framework guiding state Medicaid system modernization.
The challenge for agencies is that these standards are evolving, sometimes competing, and rarely comprehensive enough to cover all integration scenarios out of the box.
Funding Realities
Federal funding for HHS systems modernization typically comes with interoperability requirements, but the specifics vary by program and change over time:
- CMS enhanced funding (90/10 for design, 75/25 for operations) requires adherence to modularity and interoperability standards
- ACF funding for child welfare systems includes specific technology requirements
- SNAP and TANF technology funding has its own rules and expectations
Agencies must often coordinate multiple funding streams with different requirements, timelines, and oversight bodies. This creates complexity in project planning and vendor procurement.
Enforcement and Accountability
Interoperability mandates have historically been easier to issue than to enforce. However, several trends suggest increased accountability:
- Federal oversight is becoming more sophisticated at measuring actual interoperability outcomes rather than just accepting paper compliance
- Audits are increasingly examining whether funded systems actually achieve the data sharing promised in proposals
- New regulations include specific technical requirements rather than just general interoperability language
Practical Steps Forward
For agencies navigating this landscape, we recommend:
- Inventory current data sharing: Document what data currently flows between systems, how, and what gaps exist.
- Map to standards: Identify which standards apply to your data domains and assess current compliance.
- Engage stakeholders early: Interoperability requires agreement among multiple parties. Start those conversations before technical implementation.
- Build for flexibility: Standards will continue evolving. Architect systems to adapt rather than hardcoding today's specifications.
- Plan for governance: Technical interoperability is necessary but not sufficient. Data sharing agreements, consent management, and ongoing coordination require governance structures.
Looking Ahead
The direction is clear: HHS systems will become more interconnected over time. Agencies that invest thoughtfully in interoperability infrastructure now will be better positioned to meet future requirements and—more importantly—better serve the people who depend on their programs.
Interoperability isn't just a technical requirement—it's the foundation for person-centered services that meet people where they are.