Three Changes Have Finally Made EHR Evidence Underwriter-Grade

In a rapidly evolving healthcare data landscape, we explore EHR trends for underwriters and why these developments finally make EHR evidence underwriting-grade.

For more than a decade Electronic Health Records (EHRs) have promised to improve efficiency in life insurance underwriting. In practice, however, availability has been inconsistent, completeness uneven, and formats poorly suited to underwriting workflows.  As a result, the Attending Physician Statement (APS), despite its expensive cost and delays, has remained the underwriter’s gold standard, largely because it was the most defensible option available.

In 2026, that dynamic is rapidly changing. A convergence of regulatory enforcement, national exchange infrastructure, and modern data standards is transforming EHR access and data quality. Together, these forces have finally made EHR evidence suitable for underwriting decision-making. Three shifts have driven this change. 

The Information Blocking Rule Got Teeth and Momentum

When the Information Blocking Rule went into effect, in 2022, the federal government declared it “Data Liberation Day.”  The rule was designed to prevent EHR vendors and healthcare providers from interfering with the lawful exchange of electronic health information. However, until recently, enforcement mechanisms were limited, and industry compliance was uneven. 

That changed beginning in 2024, when penalties for EHR vendors were formally introduced – up to $1 million per occurrence for EHR vendors and significant Medicare financial disincentives for providers. Even then, government regulators allowed a grace period for the industry to adapt and comply with the rule.

In the fall of 2025, the US Department of Health & Human Services (HHS) signaled a clear shift. In an official press release, HHS declared a “crackdown” on information blocking, stating that enforcement is now a priority and that organizations found to be restricting lawful access to health data would face consequences.

The Pipes are Primed for Data to Flow

While Health Information Exchanges (HIE) have been around since the early 2000s, they’ve failed to provide consistent access outside the “treatment” use case.  Patient requests have seldom been fulfilled on the networks, due to insufficient incentives and trust.  A renewed federal push is enabling a new national network, the Trusted Exchange Framework and Common Agreement (TEFCA).  Most of the major EHR vendors have signed on as portions of this new network (Qualified Health Information Networks, or QHINs), bringing both data and ready-made infrastructure.  

The big change, for underwriters, is the requirement for all QHINs to provide Individual Access Services (IAS).  This unlocks the record for patients.  Patients use certified identity services like ID.me and CLEAR.com, to satisfy HIPAA and health system privacy protections.  Use cases like underwriting and claim adjudication were largely unsupported by the old networks, but in 2026 failure to provide access when the individual requests it is considered info-blocking, with significant penalties finally in place.  As the network gains momentum, TEFCA IAS represents an important pillar of individual access, but not a complete solution on its own. 

In parallel, federally mandated direct patient-mediated access methods, called FHIR endpoints, provide a complementary and often more direct path to EHR access.  Even health systems and EHRs who are participating in the new network are opening and supporting these endpoints in order to avoid penalties under info-blocking and to provide a patient’s legal right to access their records with the app of their choice.  

For innovative underwriters, consistent EHR retrieval is now achievable only by combining national exchange access with direct patient-mediated methods, rather than relying on any single network.  

Broader and Deeper—New Standards and AI Assistance 

Two federally mandated standards are driving the quality and completeness of EHR sharing. 

First, the Fast Healthcare Interoperability Resource (FHIR) is an HL7 standard that makes the healthcare data more uniform and machine-readable.  This standard governs the consistency of the data when it’s shared, and enables innovation and automation, including with artificial intelligence (AI).  

Second, as of January 1, 2026, certified EHR systems must also comply with United States Core Data for Interoperability version 3 (USCDI v3).  This standard governs the scope and completeness of the data shared electronically, and includes several important additions relevant to underwriting:

• Social Determinants of Health (SDOH) 
• Expanded Demographic & Equity Data, including sexual orientation, gender identity, and more detailed race and ethnicity data
• Expanded Provenance data, improving visibility into where specific data originated and helping identify additional medical records sources that may need to be accessed prior to a decision

Major EHR vendors including Epic, Oracle (Cerner), Athena, eClinicalWorks, and most of the other large EHR vendors now support and comply with FHIR and USCDI standards.

For underwriters, FHIR and USCDI v3 improve not just data volume, but confidence by clarifying origin, reducing ambiguity, and signaling when additional data sources may exist.

In parallel, the growing adoption of ambient AI scribe technology is improving the quality, completeness, and consistency of clinical documentation. By automatically capturing clinical conversations and ensuring key data elements are recorded, these tools help close documentation gaps caused by time pressure or human error.  They also reduce administrative burden and provider burnout – two persistent challenges in healthcare delivery nationwide.  Large health systems such as Kaiser Permanente have already deployed automated scribes at scale for over 7000 of their physicians.  All major EHR vendors now offer this AI assistance.

The Need for Speed: Why Make Your AI Wait?

Together, these regulatory, infrastructure, and standards-based improvements on individual access to records are accelerating EHR data liquidity.  For underwriting organizations, this raises an important question: why wait days or weeks for a paper-based APS PDF, derived from an EHR, when both human and machine-readable data can be retrieved directly from the source in minutes?  

As underwriting organizations increasingly rely on automated rules, analytics, and decision support, delays in evidence acquisition become a bottleneck. Faster access to structured EHR data enables quicker decisions without sacrificing confidence or defensibility.

Conclusion: The EHR Data Inflection Point for Underwriting

For years, EHRs have hovered on the periphery of underwriting. They promised efficiency, but rarely delivered the consistency, completeness, or defensibility required for confident risk decisions. That era is ending.

Regulatory enforcement has made patient access a legal expectation, not a courtesy. National exchange infrastructure is finally designed to support individual access at scale. Modern interoperability standards combined with improvements in clinical documentation are producing records that are broader, more structured, and more reliable than ever before. Together, these forces have pushed EHR evidence past a critical threshold…from experimental to underwriting-grade.

This does not mean the APS disappears overnight, but it does mean underwriters now have a credible alternative for many use cases—one that is faster, more consistent, and increasingly machine-readable by design. As EHR data liquidity accelerates, the competitive advantage will shift to organizations that can evaluate risk quickly without compromising decision quality.

The question is no longer whether EHR data can support underwriting. The question is how quickly will underwriting organizations adapt their evidence strategies to take advantage of what is now possible.

Call to Action: What Underwriting Leaders Should Do Next

Forward-looking underwriting teams should begin reassessing long-held assumptions about evidence and workflow. Specifically:

• Revisit evidence hierarchies to identify where EHR data can reliably replace or triage traditional APS requests.
• Evaluate speed-to-decision opportunities enabled by structured, electronic data that arrives in minutes rather than weeks.
• Prepare underwriting rules and governance for a future where machine-readable data increasingly powers both human and automated decisions.
• Choose partners and platforms that understand not just access to EHRs, but how to deliver standardized, decision-ready records at scale.

EHR data is no longer the future of underwriting, it is the present. The organizations that recognize this inflection point early will be best positioned to improve placement rates, reduce cycle times, and compete in an underwriting landscape where speed and confidence matter more than ever.

About Greenlight Health Data Solutions

Greenlight Health Data Solutions helps insurers access and standardize medical records for critical decision-making. Through patient-mediated data access, national exchange connectivity, and advanced data acquisition methods, Greenlight delivers structured, decision-ready medical records that support underwriting and evidence identification – reducing reliance on slow, paper-based workflows. 

Greenlight’s platform is designed to enable faster, more confident decisions while meeting evolving regulatory and privacy requirements across the healthcare and insurance ecosystems.