Healthcare has spent years pursuing interoperability. Clinical notes, laboratory results, medication histories and other health information increasingly move electronically among providers and patients.
Diagnostic imaging remains a notable exception.
When a patient moves from one health system to another, sharing an X-ray, CT scan, MRI or other diagnostic image can still involve processes that feel surprisingly disconnected from the rest of modern healthcare. Patients may be asked to obtain a CD or DVD, carry it to another provider and hope that the receiving organization can successfully open and import the files.
The persistence of physical media is more than an inconvenience. When clinicians cannot quickly access prior imaging, treatment decisions can be delayed, staff may spend time tracking down studies and patients can become responsible for transporting information between organizations that otherwise operate sophisticated digital environments.
The federal government has now placed greater attention on the issue. In January 2026, the Assistant Secretary for Technology Policy/Office of the National Coordinator for Health Information Technology issued a request for information examining diagnostic imaging interoperability standards and potential certification criteria for health IT.
The request describes an imaging ecosystem in which exchange can remain manual, burdensome and unreliable, with continued reliance on physical media creating barriers to timely care.
For health systems, the message is increasingly difficult to ignore: Medical imaging needs to become as portable as the patients whose care depends on it.
The CD Is a Symptom of a Larger Problem
The most visible problem with physical media is the CD itself.
Discs can be lost or damaged. Patients can forget to bring them. Receiving organizations may have difficulty opening them or importing their contents into local systems. Even when the process works, employees may need to manually handle the transfer before clinicians can review the images.
But eliminating CDs alone does not solve imaging interoperability.
The underlying problem is that diagnostic images often reside outside the electronic health record in picture archiving and communication systems, vendor-neutral archives and other imaging platforms. Within a health system, clinicians may have relatively seamless access to studies produced by their own organization. Crossing organizational boundaries can be considerably more complicated.
That becomes increasingly problematic as healthcare delivery expands beyond individual hospitals.
Patients receive care across health systems, independent physician groups, imaging centers, ambulatory facilities and specialty practices. A patient transferred to another hospital may need prior images immediately. An oncologist may need to compare a current scan with a study performed elsewhere months earlier. A specialist providing a second opinion may need access to the original images rather than only the radiology report.
In each situation, the clinical question crosses an organizational boundary.
The imaging infrastructure needs to cross it as well.
Imaging Delays Can Become Care Delays
Diagnostic imaging is not simply another type of data moving through the healthcare system.
Images frequently influence immediate clinical decisions.
A physician evaluating a patient may need to determine whether a finding is new, whether a condition has progressed or whether additional imaging is necessary. Without access to previous studies, clinicians may have an incomplete picture of the patient’s history.
The problem becomes particularly significant during transfers and referrals.
If images must be requested, copied, downloaded, uploaded or manually imported before another clinician can review them, administrative friction becomes part of the clinical timeline.
Sometimes clinicians may decide that waiting is inappropriate and order another study.
That may be the correct clinical decision in some circumstances. However, unnecessary duplicate imaging can expose patients to additional inconvenience, cost and, depending on the modality, radiation or contrast agents.
The federal diagnostic imaging RFI specifically identifies enhanced image access as an opportunity to improve care and health outcomes while decreasing duplicative imaging and reducing healthcare costs.
Modernizing image exchange therefore should not be viewed solely as an IT efficiency project.
It is part of reducing the distance between information and clinical action.
Stop Making Patients the Interface
One of the clearest signs that interoperability has failed is when the patient becomes responsible for making two sophisticated healthcare organizations communicate.
A patient may be instructed to contact one hospital, request imaging, obtain a disc and physically deliver it to another organization. In other cases, patients may need to navigate separate portals or download processes without knowing whether the receiving clinician will be able to access what they provide.
The burden becomes especially problematic for patients managing serious illnesses.
Someone seeking cancer treatment, preparing for surgery or obtaining a second opinion should not also have to become an expert in medical image exchange.
The technology exists to create a different experience.
Cloud-connected image-sharing environments can allow authorized organizations to make imaging available electronically rather than moving information through physical media. Instead of transporting the image, the system provides appropriate access to it.
That distinction changes the patient’s role.
The individual no longer has to function as the delivery mechanism connecting two healthcare organizations.
Cloud Connectivity Changes the Exchange Model
Traditional image exchange often focuses on moving files from one organization to another.
Cloud-native approaches can shift the model toward secure access.
Images can be made available to authorized clinicians across organizational boundaries without requiring a disc to be burned, transported and manually ingested at the destination.
For health systems operating multiple hospitals, ambulatory facilities and acquired practices, that architecture can also make imaging more accessible across the enterprise.
The opportunity is particularly important during growth.
Health systems frequently inherit different imaging platforms as they acquire hospitals, physician practices or imaging centers. Replacing every system immediately may be impractical. A scalable exchange layer can help connect those environments while organizations work through longer-term technology strategies.
The objective should not simply be to put imaging “in the cloud.” Cloud infrastructure by itself does not guarantee interoperability.
The value comes from using standards-based approaches that allow images and associated information to be accessed consistently across systems and care settings.
Standards Matter More Than Storage Location
Healthcare leaders should be careful not to treat cloud migration and interoperability as synonymous.
An image can be stored in the cloud and remain difficult to exchange if the surrounding technology depends on proprietary connections or incompatible workflows.
The federal government’s interest reflects this distinction.
ASTP/ONC is examining whether technical standards and certification criteria could improve access, exchange and use of diagnostic images through certified health IT. Among the approaches under consideration are established standards and frameworks used in medical imaging and health information exchange, including DICOM, DICOMweb, FHIR and IHE profiles.
The direction is important for health system technology strategy.
Organizations making new imaging investments should evaluate not only storage capacity, performance and cost but how easily those platforms can participate in broader interoperable environments.
Can an outside clinician obtain appropriate access without a custom integration?
Can the organization receive images from another system without manual intervention?
Can patients access their own images through modern digital tools?
Can imaging information connect appropriately with the clinical context available through the EHR?
Those questions are increasingly as important as where the image itself resides.
The Workflow Savings Can Be Significant
Physical media also creates an operational burden that can become invisible because healthcare organizations have managed it for so long.
Someone has to respond to imaging requests. Employees may need to locate studies, burn discs, package them and coordinate pickup or delivery. Receiving organizations may have to retrieve the media, determine whether it can be opened and import the study into their own imaging environment.
When something goes wrong, employees on both sides may spend additional time resolving the problem.
The cost is distributed across radiology departments, health information management, IT, clinical teams and administrative staff, making it difficult to see as a single expense.
Health systems considering modernization should therefore establish the cost of their current processes.
How many discs are produced each month? How much staff time is required to process outside imaging requests? How frequently do clinicians encounter missing studies? How long does it take to make an outside study available for clinical review? How often must employees troubleshoot failed transfers?
Those measures can help leaders build a business case that extends beyond the price of physical media.
The more meaningful ROI may come from removing manual work from the imaging journey.
Image Exchange Should Follow the Patient Journey
A modern imaging strategy should also consider how patients actually move through healthcare.
Imaging does not exist as an isolated radiology workflow. It accompanies referrals, emergency transfers, surgeries, oncology treatment, orthopedic care, neurological evaluations and countless other clinical journeys.
That means health systems should map where image exchange creates friction across those journeys.
A patient transferred from a community hospital to a tertiary medical center represents one use case. A patient seeking a second opinion from an oncologist represents another. An orthopedic patient bringing an MRI from an independent imaging center creates a different workflow.
For each scenario, leaders should ask how long it takes for the receiving clinician to see the actual study and how many people or manual steps are required to make that happen.
The goal should be for imaging to arrive as part of the care transition rather than as a separate administrative task that someone must complete afterward.
Patient Access Should Be Part of the Strategy
Interoperability is not only provider-to-provider.
Patients increasingly expect to access their health information digitally, and diagnostic images should be part of that evolution.
The federal RFI specifically notes limitations in patients’ ability to access their own images through modern application programming interface-driven tools.
Giving patients digital access does not mean shifting responsibility for exchange back onto them. A patient should be able to view, obtain and share their information without becoming responsible for manually connecting healthcare organizations.
A modern model can support both goals: direct patient access and seamless provider-to-provider exchange.
That gives patients greater control over their health information while reducing their role as the courier responsible for moving it.
Regulatory Momentum Changes the Conversation
The 2026 RFI does not itself establish new mandatory imaging interoperability requirements. It is intended to inform potential future rulemaking.
That distinction is important.
Health systems should not treat proposed approaches as finalized federal requirements.
They should, however, pay attention to the direction of travel.
Federal health IT policy has spent years advancing standardized electronic access and exchange. Diagnostic imaging is now receiving more explicit attention within that interoperability agenda.
Organizations continuing to invest in imaging infrastructure should therefore consider whether those investments position them for a more standards-based future or reinforce processes that may become increasingly difficult to defend.
A system purchased today could remain in service for years. Waiting until interoperability requirements are finalized before considering modernization may leave organizations with expensive legacy workflows that are harder to change later.
Build for Interoperability, Not Just Compliance
Regulation can provide an important catalyst, but health systems have reasons to modernize imaging exchange even without a federal mandate.
Faster access can help clinicians make decisions with more complete information. Electronic exchange can reduce the administrative work associated with physical media. Patients can encounter fewer obstacles when moving among providers. Organizations can reduce the risk that prior imaging becomes unavailable simply because it resides somewhere else.
Those are operational and clinical advantages independent of compliance.
Health systems evaluating cloud-connected image sharing should therefore look beyond whether a solution can satisfy a particular technical requirement. They should examine whether it fits naturally into clinical workflows, works across the organization’s imaging environment and reduces rather than relocates administrative burden.
Security and governance must also remain central. Diagnostic images contain protected health information, and broader electronic access requires appropriate authentication, authorization, auditing and privacy controls.
Modernization should make imaging easier to exchange without making it less secure.
The Future of Imaging Cannot Be a Disc
Healthcare’s continued reliance on physical media for diagnostic imaging reflects a larger interoperability challenge.
Health systems have digitized enormous portions of clinical care, yet some of the most important information used to make diagnostic and treatment decisions can still become difficult to access as soon as a patient crosses an organizational boundary.
Cloud-connected, standards-based image exchange offers an opportunity to change that model.
The objective is not simply to eliminate CDs. It is to create an environment in which clinicians can obtain the imaging they need when they need it, patients can move between organizations without carrying their records with them and health systems can reduce the manual work required to connect care.
Federal regulators are now examining how standards and certification might accelerate that transition.
Health systems do not need to wait for a final rule to recognize the underlying problem.
A diagnostic image can influence a clinical decision within minutes.
Moving that image between healthcare organizations should not take longer than the care it is intended to inform.
