As CMS advances its Health Data, Technology, and Interoperability Framework and the Aligned Networks Pledge, the healthcare industry faces both a challenge and an opportunity: to connect trusted networks in ways that are technically robust, operationally sustainable, and financially viable.
The HL7 FHIR® at Scale Taskforce (FAST) has been working closely with CMS and industry partners to define the scalable technical foundation that makes this vision achievable. FAST’s work delivers reusable building blocks that enable secure identity, trust, consent, and directory exchange across CMS-aligned networks.
From Policy to Performance: Why FAST Matters to Business Leaders
FAST standards are not just compliance artifacts—they are strategic enablers of digital transformation that deliver measurable value. This includes:
- Operational Efficiency: Eliminates redundant integrations, reducing onboarding and maintenance costs
- Risk Reduction: Automated credential management minimizes exposure from compromised endpoints
- Accelerated Innovation: Common APIs and reusable patterns allow solutions to scale across multiple networks
- Regulatory Readiness: Ensures alignment with CMS, ONC, and TEFCA frameworks—strengthening readiness for value-based care
“FAST is providing the trusted, scalable foundation that enables the CMS Aligned Networks vision to come to life,” said Janice Reese, FAST Program Manager.
FAST Security & Identity: Trust and Confidence at Scale
This winter marks a milestone with the publication of FAST Security IG (STU 2) and FAST Identity IG (STU 2).
- FAST Security IG (Scalable Trust): Defines how networks establish, maintain, and revoke trust using certificate-based UDAP profiles—supporting dynamic client registration and automated trust lifecycle management
- FAST Identity IG (Federated Identity for Scalable Exchange): Defines FHIR-based workflows for federated identity resolution and participant discovery, aligned with NIST 800-63 identity assurance levels
Together, these guides form the foundation of trust and confidence—ensuring that every transaction begins with verified participants, trusted credentials, and interoperable authorization.
FAST Consent: Scalable Consent Management for a Connected Ecosystem
As interoperability expands, one question continues to surface across every conversation:
“How do we manage consent in a way that’s scalable, secure, and respects individual choice?”
The new FAST Consent Implementation Guide answers that question and provides the missing piece in healthcare’s digital trust fabric. It defines how networks can capture, communicate, and honor consent decisions consistently across systems, in real time.
“FAST Consent gives patients a voice, implementers a roadmap, and networks a shared standard for trust.”
From Policy Promise to Practical Reality
Today, healthcare organizations are juggling an array of consent processes—forms, signatures, local databases, and policy interpretations that rarely align across systems. FAST Consent changes by establishing standardized, FHIR-based workflows for how consent is created, updated, searched and shared.
Instead of a single centralized consent repository, FAST Consent supports a federated model where many organizations can maintain their own consent services while remaining interoperable. That means consent decisions made in one system can be recognized and respected by another, securely and automatically.
Designed for the Modern Data Ecosystem
The IG focuses on consent administration, not on access enforcement. This means it provides the infrastructure for creating, updating, and propagating consent records, while allowing organizations to apply their own enforcement policies.
FAST Consent replaces traditional polling with FHIR Subscriptions, enabling real-time notifications whenever consent changes. If a patient revokes permission, connected systems immediately prevent data sharing that’s out of date or out of bounds.
Key operations include:
- File-Consent and Revoke-Consent: To record or withdraw consent
- Consent-Search—to find existing consents relevant to a particular transaction
- Disclosure Tracking—providing transparency into “who consulted my consent?” even if no data was ultimately exchanged
These capabilities deliver a new level of accountability and traceability, addressing a core issue raised during Connectathon testing: how to confirm that consent was obtained before data was moved.
Testing, Traceability, and Quality by Design
To ensure the IG is actionable, the FAST team worked with AEGIS to develop a Scalable Consent Management Testing Guide. It includes:
- A Requirements Traceability Matrix (RTM) mapping formal requirements to test cases
- FHIR R5 conformance resources like TestPlan and ActorDefinition to ensure normative consistency
- Executable examples that verify implementation behavior across JSON/XML formats
- A Coverage Matrix showing where testing is strong and where more validation is needed
This pairing of specification and testing allows product developers, payers, and HIEs to build, test, and validate their implementations with measurable confidence.
Why FAST Consent Matters
At its core, FAST Consent is about trust and transparency. It empowers patients to control how their data is shared while giving implementers a scalable way to honor those preferences across organizational boundaries and technical ecosystems.
It also bridges a critical gap between FAST Identity (knowing who is involved) and FAST Security (ensuring trust and authorization). Together, they enable a connected network in which every transaction is verified, consented to, and compliant.
When this article was written, FAST Consent targeted a freeze in mid-November 2025, with readiness for the December 2025 ballot—positioning it for testing at the January 2026 HL7 Connectathon.
FAST National Directory: The Backbone of Network Transparency
The FAST National Directory IG (NDH IG) serves as the technical reference for the CMS National Provider Directory and a cornerstone of the CMS Interoperability Framework.
Key capabilities include:
- Standardized Data Exchange Models: Defines FHIR resources for organizations, practitioners, endpoints, and networks
- Authoritative Source-to-Network Flow: Enables validated data from payers, boards, and CMS to flow into national and local directories
- Validation and Provenance: Adds metadata for attribution, stewardship, and transparency
- Federated Query & Synchronization: Supports real-time, subscription-based updates across networks
FAST NDH STU 2 builds upon STU 1 (Sept 2023) with enhanced metadata, validation, and federation models and aligns with CMS’s Network Connectivity & Transparency priorities.
The Foundation Architecture for CMS Interoperability
| FAST Component | Role in CMS Framework |
| Security (STU 2) | Establishes scalable trust and credential lifecycle management |
| Identity (STU 2) | Defines federated identity resolution and participant discovery |
| Consent (Ballot Jan 2026) | Enables interoperable, privacy-respecting consent management |
| National Directory (STU 2) | Provides authoritative data models for organizations, networks, and endpoints |
Together, these components form the foundation architecture supporting CMS-aligned networks, linking policy, technology, and performance into a unified, reusable framework.
Collaboration and the Road Ahead
FAST continues to collaborate with The Sequoia Project, Da Vinci, DirectTrust, CommonWell Health Alliance, and eHealth Exchange to align across trust, identity, consent, and directory efforts.
This work drives real-world interoperability, enabling payers, providers, and health IT networks to connect securely without custom integrations.
Join FAST at the HL7 Virtual Connectathon
January 13–15, 2026
Education and testing tracks will cover Security, Identity, Consent, and Directory, helping participants prepare for CMS compliance and TEFCA connectivity.
Join FAST in 2026
FAST invites networks, payers, providers, and technology partners to participate in building the trusted, scalable infrastructure that powers the CMS Interoperability Framework and the Aligned Networks Pledge.
