by Alexandra (Ford) Hubach RHIA, MSHI, CRCR & Frantia Dozier, RHIA
FHIR for the HIM Professional
Key Considerations for FHIR Related Discussions
Executive Position Statement
What is FHIR
FHIR stands for Fast Healthcare Interoperability Resources. It is a next level interoperability standard created by HL7. FHIR, developed by Health Level Seven International (HL7), is a standard for health information exchange using RESTful APIs and structured data 'Resources' (e.g., Patient, Observation, Condition, Encounter, Medication Request). Certified health IT systems are required to support FHIR-based APIs to enable standardized access to United States Core Data for Interoperability (USCDI) elements under the 21st Century Cures Act Final Rule.
Why is This Important?
In the CMS Interoperability and Patient Access final rule, CMS required certain payers to implement an HL7 FHIR Patient Access API. CMS is requiring some payers to add information about prior authorizations (excluding those for drugs) to the data available via that Patient Access API. This will empower patients to access to more of their data and help them understand the prior authorization process. This requirement must be implemented by January 1, 2027. FHIR is also enforced in the ONC 21st Century Cures Act Final Rule*, which requires standardized API access to defined United States Core Data for Interoperability (USCDI) data elements and prohibits information blocking practices. FHIR standardizes transport, but does not ensure data quality. Data governance remains HIM responsibility. FHIR increases accountability for terminology mapping, provenance tracking, and audit controls. HIM professionals should manage these mapping, tracking and audit processes to ensure patient privacy and regulation compliance.Key Considerations for the HIM Professional
HIM professionals should always have a seat at the table for discussions regarding the exchange of healthcare related data. Key Questions to ask yourself and stakeholders in your organization include:
- Do you understand the encryption and data security mechanisms?
- What is the data security and audit policy for the exchange?
- What is the turn around on security risks?
- What are your responsibilities, under the standards in the AHIMA data governance practice brief, to ensure data quality, data governance, and best practices?
- FHIR transmits data exactly as documented; free text documentation limits interoperability and downstream usability; how can your organization be a good steward of your data and maximize data assets?
- What are all the interfaces sending PHI using FHIR? Are they cataloged and routinely validated?
AHIMA. “Healthcare Data Governance.” AHIMA Body of Knowledge, https://bok.ahima.org/topics/healthcare-data-lifecycle/healthcare-data-governance/..
Centers for Medicare & Medicaid Services. Interoperability and Patient Access Final Rule (CMS‑9115‑F). 2020.
Centers for Medicare & Medicaid Services. “CMS Interoperability and Prior Authorization Final Rule (CMS‑0057‑F).” CMS.gov, https://www.cms.gov/newsroom/fact-sheets/cms-interoperability-and-prior-authorization-final-rule-cms-0057-f.
HealthIT.gov. . What Is FHIR? Fact Sheet. Office of the National Coordinator for Health Information Technology, Apr. 2021, https://www.healthit.gov/sites/default/files/page/2021-04/What%20Is%20FHIR%20Fact%20Sheet.pdf.
Healthcare Financial Management Association. ONC 21st Century Cures Act Final Rule Summary. HFMA, Oct. 2022, www.hfma.org/wp-content/uploads/2022/10/onc-cures-act-final-rule-summary.pdf.HL7 International. “FHIR Overview.” HL7.org, https://www.hl7.org/fhir/overview.html.
Office of the National Coordinator for Health Information Technology. 21st Century Cures Act Final Rule (45 CFR Part 170). 2020.
Office of the National Coordinator for Health Information Technology. United States Core Data for Interoperability (USCDI).









