Modernizing Medicaid with MITA 3.0 and the CMS Interoperability Framework

As healthcare continues its digital transformation, Medicaid programs face mounting pressure to modernize their IT infrastructure, improve data exchange, and enhance service delivery. The good news is modernization doesn’t have to mean more regulation.

MITA 3.0: Medicaid’s Tech Blueprint

Developed by the Centers for Medicare & Medicaid Services (CMS), the Medicaid Information Technology Architecture (MITA) 3.0 hopes to usher in an era of modular, cloud-based systems across Medicaid, featuring reusable, interoperable components aligned with the following legislation:

• Health Information Technology for Economic and Clinical Health Act (HITECH)
• Children’s Health Insurance Program Reauthorization Act (CHIPRA)
• Affordable Care Act (ACA)
• Health Insurance Portability and Accountability Act (HIPAA)

Much like AI and virtual reality are revolutionizing clinical care, MITA 3.0 aims to empower agencies to make smarter decisions, reduce inefficiencies, and lay the groundwork for faster, more flexible innovation.

The CMS Interoperability Framework: Voluntary, Yet Groundbreaking

Announced at the White House in July 2025, the CMS Interoperability Framework invites networks, payers, electronic health records (EHRs), providers, and app developers to voluntarily align around open, standards-based data exchange by Q1 2026. Over 60 organizations, including top health systems and tech companies like Amazon, Anthropic, Apple, Google, and OpenAI, have already signed on.

CMS’s Interoperability Framework complements MITA 3.0 by providing voluntary objectives for health data exchange. It’s designed to be market-friendly, patient-centered, and open to all networks. Rather than imposing new regulations, the framework promotes alignment, execution, and momentum.

Together, MITA 3.0 and the CMS Interoperability Framework prioritize alignment, transparency, and patient-centered care. These frameworks encourage states to move beyond legacy systems and embrace open solutions that support seamless communication across providers, payers, and digital health platforms.

Key Criteria for Participation

The Interoperability Framework outlines five core areas:

1. Patient Access & Empowerment

Patients must be able to access their medical data (structured and unstructured) through apps of their choice, without needing to know specific portals or providers. Digital identity credentials (e.g., mobile driver’s licenses, passkeys) will streamline access. Audit logs and consent preferences must be transparent and shared across the network.

2. Provider Access & Delegation

Providers using verified credentials can access full patient records for treatment. Delegated vendors acting on behalf of providers must have HIPAA-compliant agreements and are treated as direct actors. Open quality gap queries and claims-based encounter access are also supported.

3. Data Availability & Standards Compliance

All data must be returned in human- and machine-readable formats, aligned with United States Core Data for Interoperability (USCDI) v3 standards. By July 4, 2026, networks must support Fast Healthcare Interoperability Resources (FHIR) Application Programming Interfaces (APIs), bulk data exchange, and encounter notifications.

4. Network Connectivity & Transparency

Networks must publish membership details, update the CMS National Provider Directory, and share usage metrics. Inter-network connectivity and targeted queries are required to support federated data exchange.

5. Identity, Security & Trust

All queries must include a lawful purpose. Digital credentials must be accepted, and access controls enforced. Health Information Trust Alliance (HITRUST) certification or equivalent security validation is required, alongside audit logs and consent tracking.

Benefits for Healthcare Organizations

For Medicaid agencies and healthcare organizations, MITA 3.0 and the CMS Interoperability Framework represent a strategic opportunity to modernize infrastructure, improve patient outcomes, and reduce administrative burden. By aligning with these frameworks, organizations can:

• Cut costs and tap funding opportunities: MITA 3.0 helps states access enhanced federal match incentives and reduce development burdens through reusable, standardized components
• Strengthen data integrity and empower stakeholders: Improve accuracy and accessibility while enabling real-time access for patients and providers
• Future-proof your strategy: Aligning with these frameworks supports scalable, sustainable growth

We Can Help

At Elliott Davis, we help healthcare organizations implement technology solutions and perform assessments that drive operational excellence. Whether you’re preparing for MITA 3.0 adoption, aligning with CMS interoperability standards, conducting readiness assessments, or strengthening cybersecurity, our team is ready to support your transformation.

Ready to move from theory to execution? Let’s make it happen together.