We are immensely proud that health information sharing has become commonplace. Exchange is happening every day across the nation. We know navigating the complexities of modern healthcare requires more than just high-speed connections; it requires a foundation of confidence in the integrity of the data being shared, the rules of exchange, and exchange partners. At The Sequoia Project’s 2025 Annual Meeting, industry leaders gathered to discuss “Data Without Doubt,” a session on how we are maturing healthcare interoperability by examining other established sectors, such as fintech.
You trust a global banking network to move assets securely and accurately across different institutions with monitoring and alerts to flag anything suspicious. This is done by implementing integrity controls that ensure compliance with the rules through initial and continuous monitoring and enforcement.
Healthcare needs a similar trust fabric and oversight mechanisms to provide comparable levels of protection for patient information. This requires core integrity controls to ensure that every participant in a data-sharing ecosystem—from large health information networks to specialized health apps—operates under the same rigorous standards as other digitized industries.
Integrity Controls: A Framework for Certainty
Integrity controls need to be balanced, responsible, and implementable, ensuring that data sharing is both secure and practical for the real world. Accountability requires strong oversight, including controls such as:
- Exchange partners are verified before sharing information
- Trust is maintained through monitoring, regular reporting, and periodic auditing to detect and address non-compliance.
- An authority is empowered to establish compliance processes, compel cooperation in investigations, and leverage meaningful enforcement tools for non-compliance.
- A mechanism is developed to support and address complaints, with a fair and timely process to investigate, mediate, and resolve issues.
- Rigorous, tailored education and professional certification are required for those who have central roles in facilitating exchange.
- A collaborative process is put in place to maintain and update rules for privacy, cybersecurity, consumer protection, and other areas of concern to keep pace with innovation.
Why This Matters Now
For those who are participating in health information exchange today, these integrity controls will reduce risk and increase operational efficiency. By looking to mature industries such as fintech, we are moving away from “assumed compliance” and toward a system where data is a reliable asset that is moved securely and appropriately by trusted, validated participants. This is how we move toward a future of “Data Without Doubt,” ensuring not only that the right information is available at the right time, but that every transaction is appropriate and validated.
The Sequoia Project is actively working toward creating a better-connected future where data can be shared without doubt based on measurable integrity controls that we encourage all frameworks to adapt. The Sequoia Project will convene our members and the broader healthcare community this year to assess what actions, resources, and authorities are needed to implement these integrity controls for the next generation of health IT interoperability.
