A recent article in Healthy Debate rightly drew attention to the fragmentation of Canada’s health information environment and to the burden this can place on patients, clinicians, public health and system learning. However, the issue should not be framed as if success requires a single, seamless pan-Canadian record available in every setting.
Most care is still delivered within provincial and territorial systems, so the immediate task is to make information move reliably within care pathways while ensuring that essential information can also travel across jurisdictions when clinical, public-health or patient needs require it.
Interoperability requires much more than technology. It requires semantic alignment, governance, funding, workflow redesign, conformance testing, certification, procurement discipline and accountability. It also requires clarity about whose interoperability problem is being solved: the vendor’s, the provider’s, the patient’s, the public-health system’s or the health system’s learning and stewardship function. These perspectives overlap, but they are not identical. Better alignment among them will require engaged governance and realistic implementation choices.
Canada should not judge success against an unrealistic standard of total uniformity across all systems. Complete technical uniformity would be possible only if all providers used the same system, or at least the same software architecture, which is neither realistic nor necessarily desirable in a federated health system. Systems have been built to serve different clinical, organizational, jurisdictional and commercial purposes. That diversity must be acknowledged rather than wished away.
At the same time, complexity should not become an excuse for preserving fragmentation. Canada built much of its health-care governance architecture around assumptions from the 1960s and then layered digital systems onto those institutional arrangements. Those path dependencies will not be sufficient for patients, providers, public health, virtual care, Artificial Intelligence or system learning in 2026 and beyond.
A more realistic and equally meaningful objective is priority-domain interoperability. Medications, laboratory results, diagnostic imaging reports, allergies, referrals, discharge summaries and care plans should be exchanged in a timely, structured, secure and usable form across providers, organizations and, where necessary, jurisdictions. In many clinical situations, these domains are more important than access to the entirety of a patient’s record. A phone call may solve an individual case; it does not solve the system problem.
Bill S-5 should not be presented as the first step in digital health reform. Over the past decade or more, provinces and territories, often supported by Canada Health Infoway, have invested substantial resources in portals, interfaces, middleware and electronic information-sharing capacity. These intermediary systems have produced real value, but they also have limitations. The question now is whether the next stage can be made more coherent, governed, measurable and accountable.
The most practical gains will come from focusing first on the data domains that matter most to patients and clinicians, including laboratory results, diagnostic imaging, medication history, referrals, discharge information and care plans for chronic disease management. Patient and client access to these key elements of their own health record should be treated as a core objective, not an optional add-on. Portals can provide meaningful access and partial interoperability, but they should not be mistaken for full integration of all source systems across Canada’s federated health system.
Alberta’s experience is instructive. For many years, clinicians valued access to laboratory, drug and diagnostic information because those elements often provided enough information to support safer and more timely care. Patients also value access to their own records. This suggests that interoperability should be judged by its practical contribution to continuity, safety, timeliness, patient experience and provider workflow, not by whether every source system can connect seamlessly with every other source system.
Data blocking is real, but it should not be understood only as deliberate obstruction by vendors. It also reflects proprietary systems, contract terms, procurement choices, privacy interpretations, uneven standards adoption, limited conformance testing and the market realities of internationally based software suppliers. Canada is too small a market to invent a stand-alone technical standards universe. On the technical side, Canada should align with international standards such as FHIR, ISO-based approaches, terminology standards, APIs, identity management, security expectations and conformance testing.
However, harmonizing information-sharing rules, privacy expectations and security access requirements across systems and jurisdictions would assist information flow, particularly through portals and other approved access mechanisms. The United States cannot be ignored because of vendor scale and the influence of the 21st Century Cures Act, but Europe and Australia may offer more useful comparators for Canada because they also are attempting to combine common technical expectations with multi-jurisdictional governance. Eric Sutherland’s work through the pan-Canadian Health Data Strategy and the Organization for Economic Co-operation and Development reinforces the same lesson: health data reform must be internationally literate while still being domestically workable.
Each province and territory will need governance structures that reflect local requirements, but this does not mean Canada should accept 13 or 14 disconnected approaches. Canada’s greater discretion lies in the governance and practice layer: custodianship, consent, privacy, procurement, clinical workflow, public health use, secondary use, Indigenous data sovereignty, accountability and public trust. These are not secondary implementation details; they are the conditions that determine whether interoperability becomes useful, legitimate and sustainable. Funding will also be required.
Expectation management is essential. Jurisdictions are at different stages of digital maturity, and implementation will require sequencing, funding and visible measurement. The goal should be to moderate unrealistic claims without allowing complexity to become an alibi for inertia.
Successful implementation will require more than legislation. It will require a national minimum standards framework recognized and implemented by jurisdictions, semantic alignment, jurisdiction-based conformance testing, certification and more sophisticated procurement practices. Canadians need consistent expectations for core interoperability requirements, not merely technical aspirations.
The best practical approach is to focus first on priority data domains, fund the transition, measure conformance transparently and report whether the reform is improving continuity, safety, timeliness, equity and patient and provider experience.
Bill S-5 should be understood as an important but limited policy signal. It identifies a real public-interest problem and creates a federal expectation that health information should move safely and efficiently when care, public health and system learning require it. Success will depend on realistic, staged and enforceable implementation focused on meaningful interoperability rather than utopian technical uniformity. Complexity is real; it should drive better implementation design, not become an excuse for preserving fragmentation that is contrary to Canadians’ and patients’ best interests.
