Avoiding Vendor Lock-in in Healthcare: A Board-Level Guide to Owning Your Data

Executive Summary

Vendor lock-in occurs when the technical, financial, and operational costs of switching suppliers become so high that an organization feels unable to change course even when the relationship no longer serves its interests. In healthcare, this is not merely an IT inconvenience — it is a strategic and clinical risk. Lock-in erodes an organization's ability to adopt better clinical tools, to respond quickly to regulatory change, and to negotiate fair pricing at contract renewal. The financial stakes are substantial: peer-reviewed analysis finds that for large health systems, the cost of migrating away from a dominant electronic health record (EHR) ranges from hundreds of millions to over $1 billion, encompassing licensing, consulting, workflow redesign, and data conversion — one documented case, Partners HealthCare (now Mass General Brigham), budgeted $600 million for its rollout but ultimately spent $1.2 billion.[1]

This briefing is written for hospital and health-system leadership operating in the US, EU, and UK. It frames vendor lock-in as a universal governance and risk-management issue rather than a technical or regional one, and it makes a single central argument: the most effective protection against lock-in is demanding open standards at procurement time — not after a problem emerges. Regulators on both sides of the Atlantic are converging on the same principle. Contractual commitments to standards-based data export, published interoperability APIs, and full data ownership are far easier and cheaper to negotiate before signature than after. We close with CaboLabs' perspective on how open standards such as openEHR — and our openEHR-native platform, Atomik — help hospitals own their own data and clinical knowledge rather than depend on any single vendor.

Why Lock-in Is a Board-Level Risk in Healthcare

Market concentration makes the risk concrete. In the United States, the hospital EHR market has become highly consolidated: according to market-share data from KLAS Research cited in peer-reviewed analysis, one vendor, Epic Systems, provides the electronic health record for 42.3% of acute care hospitals and controls 54.9% of all acute care hospital beds, and captured nearly 70% of new hospital contracts in 2024.[1] That same peer-reviewed analysis attributes this dominance not to clear technological superiority but to structural forces such as federal incentive programs, weak interoperability requirements, high switching costs, and network effects that reinforce vendor lock-in.[1]

The underlying dynamic is not a US phenomenon; it is a healthcare-sector phenomenon that regulators in Europe and the UK are now addressing directly. The European Union's European Health Data Space (EHDS) Regulation, which entered into force in March 2025, requires all electronic health record systems placed on the EU market to comply with a common European EHR exchange format so that they are interoperable at EU level, and grants individuals a strengthened right to access and port their own electronic health data.[6] In the UK, NHS England has adopted FHIR UK Core, a national profile of the international HL7 FHIR standard, as its mandated approach to API-based interoperability across England, Scotland, Wales, and Northern Ireland, with NHS guidance stating explicitly that "it is the standard that the API conforms to that is important, not the API itself" — a principle that applies just as directly to lock-in as it does to interoperability.[7]

Unlike most industries, where changing a supplier is a temporary inconvenience, healthcare lock-in directly touches patient safety, care continuity, and regulatory compliance. When switching costs are effectively prohibitive, the incumbent gains enormous leverage in every subsequent negotiation — over price, over roadmap priorities, and over which third-party innovations a hospital is permitted to connect. Whether the pressure comes from a concentrated market (as in the US), a supranational interoperability mandate (as in the EU), or a national standards body (as in the UK), the result is the same: clinical and financial decisions are quietly constrained by a system the organization can no longer realistically leave.

Points to Consider: The Gotchas and Nuances That Decide Your Fate

Lock-in is rarely the result of a single bad decision. It accumulates through details that are easy to overlook at procurement time and expensive to unwind later, regardless of which jurisdiction you operate in. The following points deserve explicit board and procurement attention.

• Proprietary data models behind "open" APIs. A vendor can offer a standards-based API while still storing your data internally in a proprietary, undocumented schema. When you leave, the API exports a thin standardized slice while the richly structured clinical detail stays trapped in a format only the vendor understands. An API is not the same as data ownership.
• "Open" APIs that are read-only. Many published APIs let approved applications read data but not write back into the record. Read-only access means third-party tools can observe but cannot participate in the workflow, which quietly forces every meaningful clinical function back through the incumbent. Contracts should specify both read and write conformance.
• Contractual data extraction fees. The single most direct lever of lock-in is charging the customer to get its own data out. U.S. regulators have explicitly identified charging a fee to export electronic health information so a provider can switch platforms as a potential information-blocking practice,[2] and the EU's EHDS framework is built around the opposite principle — that individuals and, by extension, the organizations acting on their behalf must be able to access and port electronic health data without undue obstruction.[6] Yet fee structures tied to data volume or proprietary export tooling remain common in practice. Negotiate exit and extraction terms before signature, wherever you operate.
• Clinical content and terminology mappings trapped in vendor-specific formats. Years of investment in order sets, value sets, and terminology mappings (for example to SNOMED CT) are among the most valuable and least portable assets a hospital owns. Migrating proprietary "interface" terminologies to a reference standard is a documented, labor-intensive problem: in one mapping study, 71% of concepts were affected by a single revision of the target terminology.[4] If this knowledge lives only inside the vendor's configuration, it does not leave with you.
• Single-vendor "integrated suite" strategies. An all-from-one-vendor suite simplifies internal integration but concentrates risk. Organizations relying on a single integrated suite for every function are structurally more exposed than those using best-of-breed components connected through open integration layers. The trade-off is platform consistency versus ecosystem flexibility — and flexibility is what preserves your future bargaining power.
• Interface engine and integration costs. Every custom point-to-point interface is a small hostage. When integrations are built to a vendor's proprietary conventions rather than to published standards, each one becomes a translation that breaks when either side changes — and a cost you must rebuild if you migrate.
• Staff retraining costs. Switching costs are not only technical. Clinician retraining, workflow re-optimization, and temporary productivity loss during transition are frequently the largest real components of a migration, and incumbents know it.
• EHR-embedded analytics and decision support that don't port. Dashboards, predictive models, ambient documentation, and clinical decision support increasingly built directly into the incumbent platform typically only function within that ecosystem. As these AI-enabled features deepen, the switching cost can rise from astronomical toward practically impossible. Treat embedded analytics as a lock-in vector, not just a feature.

The Most Effective Protection: Demand Open Standards at Procurement Time

Every gotcha above is far cheaper to prevent than to cure. Before signature, a hospital has leverage; after signature, the incumbent does. The following commitments belong in the contract itself, not in a post-implementation wish list — and each is now reinforced by regulation somewhere your organization likely operates.

• Standards-based data export. Require that all clinical and operational data be exportable in published standard formats such as HL7 FHIR, at any time and without punitive fees. In the US, the ONC 21st Century Cures Act final rule established a certification criterion requiring certified health IT to export all electronic health information a product can store, specifically to support providers switching systems.[2] In the EU, the EHDS Regulation goes further by mandating a common European EHR exchange format across the market itself.[6]
• Published, conformant APIs. Require that APIs conform to published interoperability specifications and support both read and write operations. In the US, federal rules require regulated payers to expose patient and clinical data through HL7 FHIR-based APIs, establishing FHIR Release 4.0.1 as a baseline national expectation.[3] In the UK, NHS England mandates FHIR UK Core for new and migrating APIs across the health and social care system.[7] Whichever jurisdiction applies, insist on the national or supranational FHIR profile, not a vendor's proprietary variant.
• Explicit data ownership and portability. The contract should state unambiguously that the organization owns and retains full portability of its clinical and operational data, including terminology mappings, configuration, and audit metadata — independent of what any single regulation happens to require at a given moment.
• A documented data exit strategy. For each critical system, document exactly how you would migrate away from it: what data exists, in what format, how it would be extracted, and what it would cost. This is valuable both as internal governance discipline and as a negotiating signal — an incumbent that knows you have a credible exit plan negotiates differently.

Diversification: Best-of-Breed on an Open Integration Layer

Reducing lock-in is partly an architectural choice. A single integrated suite makes every function dependent on one supplier's roadmap and pricing. A best-of-breed approach — specialized components connected through an open, standards-based integration and persistence layer — distributes that dependency and preserves the ability to replace any one component without replacing everything.

The key enabler is the integration layer. Best-of-breed only reduces lock-in if the components communicate through open standards rather than brittle proprietary interfaces; otherwise the hospital simply trades one lock-in for many. This is where the persistence layer — where the data actually lives — becomes the decisive governance question.

The CaboLabs Vision: Own Your Data and Your Clinical Knowledge

CaboLabs' position is straightforward: hospitals should own their data and their clinical knowledge, and neither should be dependent on any single vendor — or on any single jurisdiction's regulatory cycle. The way to achieve this is not a better contract clause alone — it is an architecture in which the data layer is designed to outlive any individual application. Open standards make that possible, whether your organization sits under US federal rules, the EU's EHDS, or NHS England's FHIR UK Core mandate.

The open standard purpose-built for this is openEHR, an open specification for how lifelong, person-centered health records should be structured, stored, and preserved.[5] Its defining idea is a dual-model, or two-level, architecture that separates clinical knowledge from software. Clinicians and informaticians define what the data means through formal "archetypes" and "templates"; software developers focus only on how data is stored and displayed.[5] Because only the stable technical foundation is implemented in software, the clinical meaning of the data does not depend on any particular application, vendor, or region.

This directly attacks the root cause of lock-in. The typical enterprise software lifespan is 7 to 12 years, while a patient's health record must remain meaningful for a lifetime.[5] When the persistence layer is vendor-neutral and standards-based, applications can be replaced without losing or re-transforming the underlying clinical data, and multiple applications can share the same structured repository — reducing dependence on any one application supplier. The benefits that matter to leadership are governance benefits: vendor-neutral persistence, semantic interoperability, and genuine data portability.

Atomik, CaboLabs' openEHR-native clinical data repository (CDR) and demographic data repository (DDR), is built on exactly this principle. It provides a persistent, standards-based data layer that applications connect to, storing clinical and demographic information according to openEHR templates so that structure and semantics are defined separately from the software. Changing what data you collect does not require database migrations or code changes, and Atomik exposes standards-based APIs — including openEHR-compliant and FHIR-compatible interfaces, aligned with regional profiles such as FHIR UK Core where relevant — so the data remains accessible to whichever applications a hospital chooses to run, now and in the future. In CaboLabs' experience across consulting and implementation engagements in the US, EU, and UK, we deliberately build on published specifications and avoid proprietary data models wherever possible, precisely because that is what keeps a client's data and clinical knowledge in the client's hands, regardless of which regulatory regime governs them today.

For a hospital's leadership, the strategic implication is that vendor-neutral persistence turns clinical data from a liability held hostage by a supplier into a durable, portable institutional asset — the foundation on which better tools, fairer negotiations, and faster responses to regulation, in any jurisdiction, all become possible.