
Standardizing consent mechanisms removes legal uncertainty, enabling faster, secure health‑information sharing and improving patient autonomy across jurisdictions.
The health‑care ecosystem has long wrestled with the paradox of needing rich data for care coordination while respecting patient privacy. Fragmented state statutes and divergent consent practices have created a patchwork that stalls interoperable exchange, especially for sensitive information such as mental health or genetic data. By publishing targeted guidance, the Sequoia Project seeks to bridge this divide, offering a unified framework that translates legal requirements into machine‑readable rules, thereby laying the groundwork for nationwide, automated consent workflows.
The first guide, aimed at legislators, supplies model language that embeds nationally recognized technical standards—such as HL7 FHIR and the TEFCA framework—directly into state statutes. This alignment promises to reduce the interpretive burden on health‑information exchanges and ensures that privacy preferences travel with the data across state lines. The second guide translates those standards into operational playbooks for health‑care entities, detailing consent capture mechanisms, data‑use policies, and audit trails that can be executed by existing EHR and payer systems without extensive custom development. By making consent computable, organizations can honor patient choices in real time, decreasing manual processing costs and mitigating compliance risk.
For the broader industry, these guides signal a shift toward a more predictable regulatory environment, encouraging investment in interoperable technologies and fostering trust among patients. As public feedback is collected through March 13, stakeholders have a chance to shape the final recommendations, potentially accelerating adoption of automated consent solutions. In the long term, standardized, computable consent could unlock richer data flows for research, value‑based care, and AI‑driven analytics, while preserving the privacy safeguards that patients demand.
Enhancing Health Data Sharing: Sequoia Project Publishes Guides for Automated Consent & Privacy Alignment · By Pietje Kobus · February 9, 2026 · On February 9, the Sequoia Project, a VA‑based non‑profit leading nationwide health‑information‑sharing initiatives, published two guides:
Guidance to States: Legislating Technical Standard Definitions for Existing State‑Sensitive Health Data Laws – which highlights the need to align sensitive health‑data laws with national technical standards.
Operationalizing Automated Consent: Actionable Guidance for Health Care Providers, Payors, and Other Health Care Organizations – which outlines steps and provides tools for health‑care providers, health systems, payers, and their partners to collect, manage, and honor patient consent confidently, efficiently, and in a computable manner that enables automated processing.
The Guidance to States includes model language intended to support legislators and lay the foundation for enabling high‑confidence, automated systems that apply each state’s privacy rules and respect an individual’s privacy preferences regarding how sensitive health data is shared. The guide’s content benefited from extensive public input during the Sequoia Project’s public‑feedback period, the organization said.
According to a news release, the guides are a follow‑up to the non‑profit’s Moving Toward Computable Consent: A Landscape Review, a whitepaper published in April 2025 that identified current challenges to collecting, managing, and honoring patient consent in electronic health‑information exchange (HIE).
“Taken together, these two guides are practical playbooks for industry and government to work independently and collaboratively to smooth the path to a – hopefully very near – future of automated and computable consent systems,” said Kevin Day, principal business advisor at Edifecs (a Cotiviti business) and co‑chair of the Privacy & Consent Workgroup, in a statement.
“The patchwork of state and federal regulation today hinders the development of computable, automated systems to protect sensitive health data and honors patients’ requests to share – or not,” noted Melissa Soliz, partner at Coppersmith Brockelman PLC and co‑chair of the Privacy & Consent Workgroup, in a statement.
The resources were developed by the Privacy & Consent Workgroup, part of Sequoia’s Interoperability Matters program.
The guide Operationalizing Automated Consent: Actionable Guidance for Health Care Providers, Payors, and Other Health Care Organizations is open for public feedback until March 13, 2026.
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