Verifiable Credentials in Healthcare

Verifiable credentials in healthcare

Verifiable credentials in healthcare are emerging as an important digital identity technology for patient access, provider verification, consent management, and electronic health record exchange. For healthcare organizations, payers, EHR vendors, and legal teams, these credentials raise important questions about HIPAA compliance, auditability, identity assurance, data integrity, medical billing integrity, and fraud risk.

A verifiable credential is a digital credential that can be issued by a trusted party, held by a person or organization, and presented to another party for verification. In healthcare, this model may apply to patient identity credentials, provider credentials, board certifications, medical licenses, vaccination records, insurance coverage, consent preferences, and access rights to protected health information.

What Are Verifiable Credentials in Healthcare?

Verifiable credentials allow organizations to issue digital records that can be cryptographically verified, checked for integrity, and selectively shared. A credential can be stored in a digital wallet or other trusted application and presented when a verifier needs to confirm identity, qualification, authorization, or consent. This is the technical foundation of healthcare digital identity: a model in which identity, licensure, coverage, and consent can each be proven independently rather than inferred from a single static document.

The World Wide Web Consortium’s Verifiable Credentials Data Model v2.0 describes a model involving three primary roles: issuers, holders, and verifiers.¹ In a healthcare setting, examples may include:

• A state medical board issuing a verifiable medical license credential to a physician
• A healthcare organization verifying provider credentials during onboarding or privileging
• A patient using a digital credential to access electronic health records across multiple providers
• A payer or provider verifying insurance coverage or eligibility data
• A patient sharing consent preferences for specific data exchange purposes
• A healthcare application proving that a user has been identity-proofed and authenticated

Unlike ordinary scanned documents or PDF copies, verifiable credentials are designed to support machine-readable validation, tamper-evident proofing, and more granular sharing of information. However, the healthcare use case is not merely technical. It also implicates HIPAA, electronic health record integrity, audit logs, access controls, business associate relationships, and patient trust.

Why Verifiable Credentials Matter in Healthcare

Healthcare organizations depend on accurate identity verification before granting access to protected health information, processing claims, onboarding providers, or relying on electronic medical records in litigation. Verifiable credentials may reduce manual verification steps, but they also introduce new compliance questions involving authentication, authorization, consent, audit trails, chain of custody, and interoperability. These are the same questions that sit at the center of HIPAA compliance digital identity analysis: a credential is only as trustworthy as the process that issued and validated it.

For healthcare compliance and litigation, the key issue is not simply whether a digital credential exists. The more important questions are whether the credential was properly issued, whether it was valid at the time of use, whether the person or organization presenting it was authorized to act, whether the access was appropriate, and whether the system created reliable records that can later be audited.

CMS Health Tech Ecosystem and Digital Identity Momentum

In 2025, the Centers for Medicare & Medicaid Services announced its Health Tech Ecosystem and CMS Interoperability Framework in connection with broader federal and private-sector efforts to improve patient access, data sharing, provider connectivity, and digital health infrastructure.²

CMS describes the Digital Health Ecosystem as a voluntary alignment effort rather than a new regulatory mandate. The initiative encourages data networks, EHR systems, health app developers, providers, payers, and other stakeholders to align around common infrastructure for secure data access and exchange.³

The CMS Interoperability Framework is especially relevant to verifiable credentials in healthcare because its CMS-Aligned Network criteria address identity, security, trust, access controls, consent policy, and auditability. The framework includes criteria for accepting digital credentials for both patients and providers through CMS-approved identity assurance and authentication approaches, such as IAL2 or equivalent identity proofing and AAL2 authentication methods including mobile driver’s licenses and passkeys.⁴

For compliance and expert witness analysis, several elements of the CMS Interoperability Framework are particularly important:

• Acceptance of digital credentials for patients and providers
• Identity assurance and authentication using CMS-approved approaches
• Purpose-of-use declarations for requests, such as treatment, payment, healthcare operations, or individual access
• Consent-policy enforcement appropriate to the data access context
• Access controls tied to the sensitivity of the information requested
• Verifiable logs or audit records for identity and authentication requests and responses
• Security validation, such as HITRUST certification or equivalent validation approved by CMS
• Continued compliance with HIPAA Privacy and Security Rule obligations

Key Applications of Verifiable Credentials in Healthcare

Provider Credentialing, Licensing and Privileging

Provider credentialing is one of the clearest healthcare use cases for verifiable credentials. Medical boards, hospitals, health systems, payer networks, telehealth platforms, and staffing organizations all depend on accurate verification of education, training, licensure, certifications, sanctions, privileges, and work history.

Verifiable credentials may help reduce repeated manual verification, improve provider onboarding, and support more reliable confirmation of a clinician’s current authority to practice. However, credentialing workflows must still address source-of-truth validation, expiration, revocation, sanctions monitoring, delegation, and auditability.

Patient Identity Verification and Record Access

Patient identity remains a persistent challenge in healthcare. Patients often have separate portal accounts, incomplete demographic records, duplicate medical record numbers, or limited ability to access longitudinal records across providers. Verifiable credentials may help patients prove identity and request medical records without relying on repeated manual verification or fragmented portal credentials — a practical expression of healthcare digital identity at the patient level.

In a CMS-Aligned Network context, this may support patient access to electronic medical information without requiring the patient to know every provider, portal, or account connected to their records.⁴ From a litigation perspective, this raises questions about identity proofing, authentication strength, proxy access, personal representatives, consent, and the reliability of logs showing who requested or received records.

Patient Consent Management and Data Sharing

Verifiable credentials may also support patient consent management by allowing patient preferences, authorizations, or restrictions to be represented in a standardized and verifiable format. This can be relevant when data is exchanged for treatment, payment, healthcare operations, individual access, research, care coordination, or third-party application access.

However, consent represented as a digital credential does not eliminate the need to evaluate whether the underlying use or disclosure complied with HIPAA, state privacy laws, contractual restrictions, organizational policy, and the patient’s actual authorization.

Payer, Provider and App-Based Data Exchange

Digital credentials may become relevant to payer-provider data exchange, prior authorization workflows, eligibility verification, digital insurance cards, app-based access, and patient-facing health technology. These use cases may involve FHIR APIs, USCDI data elements, SMART Health Cards or Links, QR codes, and patient-facing apps connected to healthcare data networks.

When credentials are used in these workflows, organizations should be able to demonstrate who requested the data, what authority they had, what data was released, what purpose was asserted, what consent controls applied, and what logs exist to support later review.

Regulatory and Compliance Considerations

Any implementation of verifiable credentials in healthcare must be evaluated within the existing healthcare privacy, security, interoperability, and records-management environment. Important considerations include:

• HIPAA Privacy and Security Rule compliance
• HITECH Act and healthcare data privacy implications
• Electronic protected health information, or ePHI, security controls
• Administrative, physical, and technical safeguards under the HIPAA Security Rule
• Business Associate Agreements when vendors create, receive, maintain, or transmit PHI
• Minimum necessary analysis where applicable
• Identity assurance and authentication strength
• Authorization, role-based access, and purpose-of-use controls
• Patient right of access and interoperability requirements
• Information blocking considerations under the 21st Century Cures Act framework
• EHR audit logs, access reports, event logs, retention, and chain of custody
• Data integrity and reliability of electronic health records

The HIPAA Privacy Rule protects individually identifiable health information held or transmitted by covered entities and business associates, while the HIPAA Security Rule establishes standards for safeguarding electronic protected health information.⁵⁶ Verifiable credential systems used in healthcare must therefore be analyzed in light of the sensitivity of the PHI involved, the identity of the requesting party, the purpose of access, and the security controls protecting the credential workflow.

Organizations should also consider how verifiable credential workflows interact with certified health IT, FHIR-based interoperability, USCDI data classes, health information exchange, app access, and patient-mediated exchange.⁷

Expert Witness Implications for Healthcare Litigation

As verifiable credentials become part of healthcare data exchange, they may become relevant in disputes involving EHR access, HIPAA compliance, medical billing, payer-provider data exchange, provider credentialing, patient consent, and alleged misuse of protected health information.

In litigation, expert analysis may involve whether a digital credential system reliably established the identity and authority of the requester, whether EHR audit logs are complete and tamper-evident, whether patient consent preferences were honored, and whether credential-based access affected the integrity of medical records or claims data. This is the core of EHR expert witness work in credential-related disputes.

Based on my specialized knowledge as an expert, in my opinion, healthcare providers should use Certified Electronic Health Record Technology or certified Health IT Modules within a CEHRT configuration when creating, receiving, maintaining, accessing, exchanging, or transmitting electronic health information. Where applicable to the certified Health IT Module and its scope of certification, the CEHRT should satisfy relevant ONC privacy and security certification criteria, including 45 C.F.R. § 170.315(d)(1)(i), § 170.315(d)(2), § 170.315(d)(7), § 170.315(d)(9), and § 170.315(d)(12).⁸

Those criteria are directly relevant to verifiable credentials in healthcare because they address core security and evidentiary functions: verifying a user against a unique identifier, recording auditable events, protecting audit logs against alteration, encrypting electronic health information stored on end-user devices, establishing trusted connections, and encrypting stored authentication credentials. In credential-related disputes, these controls may become central to determining whether the system reliably authenticated the user, protected PHI, preserved audit evidence, and maintained the integrity of the electronic health record.

CEHRT, Emerging Credential Technologies and Vendor Claims

New and emerging technologies, including verifiable credentials, digital wallets, mobile driver’s licenses, passkeys, identity proofing services, patient-facing applications, and CMS-Aligned Network vendors, may complement CEHRT certification controls when they strengthen identity proofing, authentication, access control, consent management, trusted exchange, and auditability. For example, CMS’ Interoperability Framework contemplates digital credentials for patients and providers using IAL2 or equivalent identity proofing and AAL2 authentication methods, including mobile driver’s licenses and passkeys, and it calls for access control, consent-policy enforcement, and verifiable logs or audit records for identity and authentication requests and responses.⁴

However, these emerging technologies may also overlap with or create conflict with CEHRT privacy and security controls if they are implemented as parallel systems that bypass, duplicate, or fragment the controls required within certified health IT. Examples include vendor platforms that authenticate users outside the EHR without reconcilable EHR audit logs, issue or rely on credentials without adequate identity proofing, store electronic health information or tokens on end-user devices without appropriate encryption, transmit PHI without trusted connections, or maintain separate access logs that cannot be independently reviewed against the EHR’s audit trail.

In my opinion, vendors should not market verifiable credentials, wallets, passkeys, digital identity tools, or CMS-Aligned Network participation as a substitute for CEHRT privacy and security controls. These technologies are best understood as complementary identity, authentication, access, and exchange layers that must be implemented in a way that is consistent with CEHRT certification criteria, HIPAA Privacy and Security Rule obligations, Business Associate Agreement requirements, and the evidentiary need for complete and reliable audit logs.

Legal teams may need expert witness analysis involving:

• Whether identity assurance and authentication controls were reasonable for the sensitivity of the PHI accessed (e.g. use of a Certified Electronic Health Record Technology or “CEHRT” that complies with 45 C.F.R. § 170.315 — ONC Certification Criteria for Health IT.” Privacy and security certification criteria, including § 170.315(d)(1)(i), § 170.315(d)(2), § 170.315(d)(7), § 170.315(d)(9), and § 170.315(d)(12).
  https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-D/part-170/subpart-C/section-170.315
• Whether provider or patient credentials were valid, expired, revoked, delegated, or misused
• Whether EHR audit logs show who accessed records, when access occurred, what data was accessed, and what purpose was asserted
• Whether verifiable credential logs, wallet logs, API logs, identity-provider logs, and EHR audit logs are consistent with each other
• Whether access was consistent with HIPAA Privacy and Security Rule requirements
• Whether a vendor acted as a business associate and required a Business Associate Agreement
• Whether data exchange complied with patient consent, authorization, or access restrictions
• Whether credentialing failures contributed to billing errors, false claims, privacy violations, or medical record integrity issues
• Whether implementation met generally accepted healthcare data management, security, certification, and interoperability standards
• Whether records generated by the credential workflow are reliable enough to support or challenge legal claims

Records to Request in Discovery

In disputes involving verifiable credentials in healthcare, counsel may need to request technical, administrative, and transactional records showing how identity, authorization, consent, and access were handled. NOTE : this is an example and cannot forsee as an example the litigation case-specific materials that should be requested. There are other factors pretaining to HIPAA Privacy breaches that may be relevant.  “Cybersecurity” in healthcare generally includes HIPAA compliance, NIST Standards and may include other factors.

• Validate that if an eligible professional or eligibe hospital utilizes an electronic health record that it is a Certified Electronic Health Record Technology (“CEHRT”)
• Credential issuance records and identity proofing documentation
• Credential status, expiration, suspension, or revocation records
• Authentication logs, including IAL2, AAL2, passkey, mobile driver’s license, or identity-provider events
• Access-control rules and role-based permission settings
• Purpose-of-use declarations for treatment, payment, operations, or individual access
• Consent artifacts, patient restrictions, authorizations, and disclosure preferences
• EHR audit logs, API logs, portal logs, and third-party application access records
• Business Associate Agreements and vendor security documentation
• FHIR API transaction logs, record locator events, and data exchange metadata
• Claims, eligibility, prior authorization, and payment records connected to credential-based access
• Security documentation showing encryption of electronic health information on end-user devices
• Evidence of trusted connections, transport security, and encryption of stored authentication credentials

For electronic medical record and EHR expert witness work, verifiable credentials may affect the forensic review of audit trails, access logs, metadata, record amendments, patient portal activity, third-party app access, credential events, identity-provider logs, API access, and record disclosure histories. For HIPAA expert witness work, the same technology may be central to whether an organization implemented reasonable safeguards, access controls, authentication, encryption, trusted connections, audit review, and vendor oversight.

Medical Billing, Claims and Fraud Risk

Verifiable credentials may also have implications for medical billing, coding, claims submission, payer-provider exchange, and healthcare fraud investigations. If a credential is used to establish provider identity, patient eligibility, coverage, authorization, or access to claims-related records, then the accuracy and integrity of that credential workflow may become material — and may call for medical billing expert witness review.

Examples of billing and claims issues include:

• Whether a provider was properly credentialed or enrolled at the time services were billed
• Whether a credential was used to obtain access to patient records for billing or payment purposes
• Whether payer or provider systems relied on inaccurate digital identity or eligibility data
• Whether authentication logs support or contradict allegations of improper access or billing activity
• Whether a credentialing or access-control failure contributed to false claims, duplicate billing, or unauthorized disclosures
• Whether claims data, medical record data, and credential event logs are consistent with each other

These issues may require combined expertise in healthcare information technology, HIPAA, EHR systems, claims workflows, medical billing, coding, payer rules, and forensic review of electronic records.

Looking Ahead

Verifiable credentials in healthcare represent a significant shift in how identity, qualifications, authorization, and consent may be proven and shared. Adoption remains uneven, and implementation details matter. The compliance value of a verifiable credential depends on the reliability of the issuer, the strength of identity proofing, the security of the wallet or application, the verifier’s controls, the availability of revocation checks, and the quality of audit logs.

Healthcare organizations and legal professionals should stay informed about how digital identity technologies intersect with HIPAA, EHR access, the CMS Interoperability Framework, payer-provider data exchange, patient consent, medical billing, and healthcare litigation.

For organizations implementing verifiable credentials, the most important questions are practical and evidentiary:

• Who issued the credential?
• What identity proofing was performed?
• What authentication method was used?
• Was the credential valid at the time it was presented?
• Was the requester authorized to access the data?
• What PHI was accessed, used, disclosed, or transmitted?
• What consent or purpose-of-use controls applied?
• What EHR audit logs exist?
• Can those logs be independently reviewed?
• Do the records support the organization’s compliance position?

Healthcare Data Privacy, HIPAA, EHR Forensics, Medical Billing Expert Witness

No World Borders provides expert witness services involving healthcare data privacy, HIPAA compliance, electronic health records, medical billing, coding, payer-provider data exchange, and healthcare technology disputes. Cases involving verifiable credentials in healthcare may require analysis of identity assurance, authentication, EHR audit logs, consent, access controls, billing integrity, EHR data reliability, and medical record chain of custody.

Contact No World Borders about healthcare data privacy, HIPAA, EHR, and medical billing expert witness services.

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