What Does the Diagnostic Imaging Interoperability RFI Mean for Healthcare Organizations?

On January 30, 2026, the Assistant Secretary for Technology Policy (ASTP) and the Office of the National Coordinator for Health IT (ONC) published an imaging interoperability RFI focused on diagnostic imaging standards and certification. This signals a more serious federal push to improve how providers and patients access, exchange, and use diagnostic images.

This imaging interoperability RFI is a listening phase, not a new rule. But it is one of the clearest signals in years that diagnostic images are being pulled into the same standards-based interoperability trajectory that clinical data has been on.

For us, this is familiar territory. We have been electronically facilitating medical imaging request and release workflows for more than a decade because the operational problem has been obvious for just as long.

If your organization still moves images via CDs, portals, or manual export and import, this imaging interoperability RFI raises the stakes for vendor readiness, patient access, and compliance.

Why Are Diagnostic Imaging Records Harder to Exchange Than Other Types of Health Data?

Healthcare has made real progress in interoperability, especially for clinical documents, results, and messages. But imaging exchange has remained stubbornly inconsistent, and the reasons are structural.

Picture Archiving and Communication Systems (PACS) were built for storage and local viewing, not cross-organization exchange. DICOM is the right clinical standard, but it often means large studies that strain the infrastructure and workflows many organizations still rely on. And while EHR interoperability has had years of policy pressure and certification incentives behind it, diagnostic imaging exchange has not had the same consistent, standards-based pathway across the market.

The result is still visible in day-to-day operations. Many organizations continue to rely on physical media and manual handoffs, even when everyone involved knows the workflow is slow, unreliable, and hard to secure. The administrative burden is real, and the patient impact is real.

What Does the ASTP/ONC Imaging Interoperability RFI Actually Signal?

The imaging interoperability RFI does three important things at once.

First, it frames imaging interoperability as a national priority tied to access and timely care. ASTP/ONC is explicit about the goal: move diagnostic images out of siloed workflows and into a modern ecosystem where images can be accessed and shared more reliably.

Second, it places certification on the table. The RFI asks whether standards and certification criteria under the ONC Health IT Certification Program could improve medical image access and exchange through certified health IT (Federal Register notice). That matters because certification is one of the few levers that can change market behavior at scale.

Third, it acknowledges the lived operational pain that has been building for years, and puts it on record as a policy concern. By naming fragmented workflows, continued reliance on physical media, and gaps in patient access, the imaging interoperability RFI signals that imaging is being treated as a systemic problem requiring systemic solutions, not a technical edge case that individual organizations should solve on their own.

If you are leading imaging operations, ROI, HIM, compliance, or IT, the practical takeaway is simple: diagnostic imaging is being treated less as an edge case and more as core health information that requires a scalable, standards-based exchange model.

How Does the Imaging Interoperability RFI Relate to Patient Access?

Imaging is not optional data in modern care delivery, but the operational implications are straightforward. If a specialist cannot review prior imaging before a visit because a study is still sitting on a CD, or if a patient has to call staff to access images that should be available electronically, the issue is no longer just inconvenience. It is a critical gap in access and exchange.

This is compounded by the fact that most modern computers don’t have built-in disc drives. This means patients who receive medical images via disc are often forced to purchase external disc drives.

That matters because many organizations still treat imaging differently from other electronic health information. Clinical notes, lab results, and summaries may move through more modern workflows, while images remain stuck in processes built around physical media, one-off exports, or systems that do not communicate well between organizations.

If your imaging workflows routinely delay access, require unnecessary friction, or create avoidable barriers to exchange, you may be increasing compliance exposure in a regulatory environment that is steadily raising expectations for access, exchange, and use of EHI.

What Does a Modern Medical Image Exchange Workflow Actually Look Like?

Good imaging exchange does not feel like a project. It feels like infrastructure.

Images arrive quickly, in a standard format, and are usable without extra steps. Clinicians can review prior imaging before the appointment instead of discovering at the point of care that records are incomplete. Patients can access their images without a scavenger hunt across portals, phone calls, and mailed discs. HIM and ROI teams can fulfill requests without burning CDs, coordinating couriers, troubleshooting unreadable media, or reworking failed deliveries.

In a modern workflow, imaging is accessible through a browser-based experience, fulfillment is trackable, and the receiving party can actually use what was sent. That is the difference between technically sending images and operationally exchanging them well.

That is the experience the RFI is trying to make more common. It is also the standard we have been building toward for years.

What Should Healthcare Organizations Do Now in Response to the Imaging Interoperability RFI?

Regardless of how the imaging interoperability RFI process unfolds, the operational case for modernizing imaging exchange is already strong. The organizations that do the work now will not be forced into rushed decisions later.

Audit your current imaging workflows. Quantify how much imaging exchange still depends on physical media, point-to-point workarounds, or manual steps. Track average fulfillment time, failure points, and what percentage of incoming imaging arrives in a format that is immediately usable.

Pressure-test your vendor roadmap. If your current tools cannot support electronic imaging exchange at scale, ask direct questions now. Can the platform support standards-based exchange rather than one-off workarounds? Can recipients access images through a browser without special software? Is fulfillment trackable and auditable? Is there a clear turnaround commitment? Organizations that wait for vendors to catch up later are usually the ones scrambling when expectations become harder to ignore.

Map patient access friction. Patients increasingly expect imaging to be accessible the way other electronic data is. If your organization cannot reliably deliver imaging without physical media, special workstations, or one-off processes, that gap will become more visible as expectations rise.

If you want a practical look at the operational burden of legacy imaging workflows, start with our breakdown of the hidden costs of CD-based imaging workflows and what a modern process replaces them with.

How Can Healthcare Organizations Respond to the ASTP/ONC Imaging Interoperability RFI?

The comment period for the imaging interoperability RFI closes on March 16, 2026, at 11:59 PM ET. If your organization has firsthand experience with imaging exchange friction, this is the moment to put it on the record.

You can submit comments through the Federal Register notice or directly via Regulations.gov (Docket ID: HHS-ONC-2026-0067) under the docket.

When drafting your response, focus on operational specifics:

• Where imaging exchange breaks down today (physical media, portals, manual export/import steps, missing context)
• What good looks like in your setting (turnaround time, usability, availability at point of care, patient access)
• Which standards, workflows, or certification requirements would actually change outcomes for your teams and patients
• What unintended consequences to avoid (administrative burden, security gaps, workflows that do not fit imaging reality)

The most valuable comments will be concrete, measurable, and grounded in what teams are experiencing every day.

How Does ChartRequest Support Faster, Digital Imaging Exchange?

We did not build our imaging exchange capabilities because a regulation told us to. We built them because the status quo was not good enough for patients, providers, or the teams forced to keep legacy workflows moving.

Our platform supports the full imaging request and release workflow electronically, including workflows that traditionally depend on physical media and manual re-import steps.

A few things define the difference.

Built for large DICOM studies. Our workflows are designed to handle imaging volume and complexity without the small upload caps and brittle handoffs common in generic file-sharing approaches. That reduces failed deliveries, manual troubleshooting, and the delays that happen when teams have to fall back to physical media.

In-platform viewing. Recipients can access and review imaging without needing specialized software to simply see what they received. That matters when clinicians need timely access to prior studies, and staff should not have to troubleshoot the receiving side of every request.

A 5-day turnaround guarantee when we manage fulfillment. When a request is complete, and we manage the release process end-to-end, we guarantee release within five business days. That matters because imaging delays do not just create frustration. They slow care, create avoidable staff work, and make a modern exchange process feel less reliable than it should.

How Could the Imaging Interoperability RFI Change Future Imaging Exchange Requirements?

The imaging interoperability RFI is a window into the future direction of healthcare: more standards, more certification pressure, and higher expectations for diagnostic images to move like other critical health information.

The organizations that move now toward digital, scalable imaging exchange will be better positioned if formal requirements follow. Waiting for a mandate means being forced to change under pressure rather than on your own terms.

If you want to see what modern imaging exchange looks like in practice, we would welcome the chance to walk through your current workflow and show where we can remove delays, manual handoffs, and unnecessary friction.

Want to see what a 5-day imaging release guarantee looks like in practice? Schedule a demo to start the conversation.