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Diabetes Device Interoperability Explained: Standards, FDA Requirements, and How to Build It

Diabetes Tech Interoperability Explained: What It Is, Why It Matters, and How to Achieve It
How do CGMs, insulin pumps, and dosing algorithms from different companies work together? This guide explains diabetes device interoperability layer by layer: the Bluetooth, IEEE 11073, and HL7 FHIR standards that apply, what FDA requires of interoperable devices, how CGM data reaches the EHR, and how to build for it.

Diabetes device interoperability is the ability of glucose sensors, insulin pumps, dosing algorithms, apps, and health record systems to exchange data and use it safely. FDA defines medical device interoperability as “the ability to safely, securely, and effectively exchange and use information among one or more devices, products, technologies, or systems.” In diabetes care, that exchange is what turns a CGM, a pump, and an algorithm from different companies into one automated insulin delivery (AID) system, and what puts a patient’s glucose data in front of their clinician.

This guide explains how interoperability works layer by layer, which standards apply at each layer, what FDA expects from interoperable devices, and how device makers can build for it from the start.

What diabetes device interoperability covers

Interoperability is not a single connection but a chain of connections. Each link has its own standards, risks, and owners.

Layer
What connects
Typical technology
Device to device
CGM, insulin pump, and dosing algorithm
Bluetooth Low Energy, manufacturer interface specifications
Device to app
Sensor or pump to a phone app
Bluetooth Low Energy, Bluetooth SIG services, IEEE 11073
App to cloud
Phone app to a manufacturer or third-party platform
Secure web APIs, cloud data models
Cloud to EHR
Platform to the clinic’s electronic health record
HL7 FHIR, LOINC codes, SMART on FHIR

Early artificial pancreas systems were built mostly within a single company. Today, a sensor from one manufacturer, a pump from a second, and an algorithm from a third can work together, because the FDA created classifications for interoperable components. For the market view of who builds what, see our guide to the diabetes technology ecosystem.

Why interoperability matters

Interoperability gives each stakeholder something different:

  • People with diabetes can choose the sensor, pump, and algorithm that suit them, without giving up automation. One person may prioritize preventing lows, another tighter control.
  • Clinicians can see device data inside the tools they already use, rather than logging into a separate portal for each brand. See why EHR interoperability matters for care teams.
  • Device makers can focus on what they do best and reach more users through partners’ systems.
  • AI and analytics depend on accurate, consistent data. Fragmented formats and missing context limit what predictive models can do.

The standards map: which standards apply where

Diabetes interoperability draws on general wireless and health IT standards, plus a few built specifically for glucose and insulin data.

Standard
Layer
What it covers
Status
Bluetooth SIG Glucose Service (GLS) and Glucose Profile
Device to app
Glucose readings from a personal glucose sensor, such as a meter
Adopted; GLS v1.0 in 2012, v1.0.1 in 2022
Bluetooth SIG Continuous Glucose Monitoring Service (CGMS) and Profile (CGMP)
Device to app
Glucose and related data from a personal CGM sensor
Adopted; CGMS v1.0 in 2014, v1.0.2 in 2022
Bluetooth SIG Insulin Delivery Service (IDS) and Profile (IDP)
Device to app
Status and control of an insulin delivery device
Adopted; IDS v1.0 in 2018, v1.0.1 in 2022
IEEE 11073-10425
Device to app
Personal health device specialization for CGMs
Published 2019
IEEE 11073-10417 and 11073-10419
Device to app
Device specializations for glucose meters and insulin pumps
Published 2023 and 2024
IEEE 11073-20601
Device to app
Optimized exchange protocol for personal health devices
2022 edition; FDA-recognized consensus standard
ITU-T H.810 (Continua Design Guidelines)
Device to cloud
End-to-end guidelines for personal connected health
Version 5, 2019
HL7 FHIR CGM Implementation Guide
Cloud to EHR
CGM summary reports, metrics, and readings sent to the EHR
STU 1, published September 2025
LOINC
Cloud to EHR
Codes for CGM metrics such as time in range and glucose management indicator
Active
USCDI v3
Cloud to EHR
Baseline data set for certified health IT in the US
Required baseline from January 1, 2026
ANSI/AAMI/UL 2800-1
System
Safety standard for medical device interoperability
Published 2019
IEC 80001-1
System
Risk management for IT networks that include medical devices
Edition 2, 2021

Two caveats matter in practice. First, standards rarely cover everything a dosing system needs, so commercial AID integrations also rely on interface specifications that each manufacturer shares with its partners. FDA requires ACE pumps and iAGCs to have a process for sharing those specifications. Second, a standard only helps if both sides implement the same version, so pin versions in your interface agreements.

What FDA expects from interoperable devices

FDA addresses interoperability in two places: a general guidance for any interoperable device, and specific special controls for diabetes components.

FDA’s interoperable medical devices guidance

FDA’s final guidance, Design Considerations and Pre-market Submission Recommendations for Interoperable Medical Devices (September 2017), asks manufacturers to deliberately design each electronic interface. It lists six design considerations:

  1. The purpose of the electronic interface
  2. The anticipated users
  3. Risk management
  4. Verification and validation
  5. Labeling
  6. Use of consensus standards

In a premarket submission, FDA expects “a discussion of each externally-facing electronic interface found on the device,” covered in the device description, risk analysis, verification and validation, and labeling.

Special controls for diabetes components

The classifications for iCGMs, ACE pumps, and iAGCs go further. Their special controls spell out how these devices must communicate.

Requirement
iCGM (21 CFR 862.1355)
ACE pump (21 CFR 880.5730)
iAGC (21 CFR 862.1356)
Reliable, secure data transmission
Required: a “detailed strategy to ensure secure and reliable means of iCGM data transmission”
Required
Required
Validated interface specifications
Not specified
Required
Required
Secure authentication (pairing)
Not specified
Required
Required
Process for sharing interface specifications with connected devices
Not specified
Required
Required
Safe operation when communication fails or data is out of bounds
No clinically significant data gaps that would stop connected devices from working
Required
Required
Postmarket responsibilities across companies
Not specified
Not specified
A plan for assigning postmarket responsibilities, including adverse event reporting

The full text is in 21 CFR 862.1355, 21 CFR 880.5730, and 21 CFR 862.1356. For how FDA reviews the dosing algorithms themselves, see our guide to AI in diabetes devices. Connected devices also face cybersecurity requirements: a device with software capable of connecting to the internet is likely a “cyber device” under section 524B of the FD&C Act. See our guide to medical device cybersecurity.

Getting diabetes device data into the EHR

A person with diabetes may see several providers and use several devices, so their data often ends up in disconnected systems. Clinicians then work from partial information, or spend visit time compiling reports by hand. Three developments are changing that.

  • iCoDE. The Diabetes Technology Society’s iCoDE project (Integration of Continuous Glucose Monitoring Data into the Electronic Health Record) published consensus standards for CGM-EHR integration in its 2022 iCoDE Report. It was described as the first consensus standard for integrating data from a wearable device into the EHR. A follow-up project, iCoDE-2, focuses on insulin delivery data.
  • HL7 FHIR CGM Implementation Guide. Published by HL7 International as STU 1 in September 2025, the guide “provides a standardized approach for sharing Continuous Glucose Monitoring (CGM) data between actors.” It covers summary reports, metrics such as mean glucose, time in range, and glucose management indicators, and individual sensor readings, with a defined way for apps to submit data to the EHR.
  • LOINC codes for CGM metrics. Standard codes now exist for key metrics, such as 97510-2 for time in range and 97506-0 for glucose management indicator, so every system can label the same number the same way.

Federal rules are also raising the baseline. Under ONC’s HTI-1 rule, USCDI v3 became the data standard baseline for certified health IT on January 1, 2026. CMS’s Interoperability and Prior Authorization final rule requires many payers to support new APIs, generally beginning January 1, 2027. For device makers, the practical step is to map your data to the FHIR CGM guide and LOINC codes now, so health systems can take it in without custom work.

Why interoperability is still hard

Even with standards and clear FDA expectations, diabetes interoperability projects run into the same six problems.

Challenge
What goes wrong
How to address it
Gaps in standards
General standards lack diabetes-specific detail, so partners fill gaps with their own specifications
Use published standards first, then document every extension in a versioned interface specification
Data volume and timing
CGMs produce continuous readings, and dosing decisions depend on timely, synchronized data
Define latency, gap handling, and time-stamping rules in the interface specification
Regulatory scope
Regulators look at system-level safety, not just each device
Plan verification and validation for the combined system, under IEC 62304 and ISO 13485 processes
Cross-company collaboration
Partners differ on timelines, data models, and testing practices
Agree on a shared integration plan, test protocol, and change process before development starts
Testing and validation
Each component must work alone and in every supported combination
Build a combination test matrix and automate regression testing; see software validation for SaMD
Postmarket synchronization
Firmware updates, app releases, and security patches can break compatibility
Coordinate release schedules and require compatibility testing before any partner ships an update

Privacy rules add another layer. Data that flows to clinicians may fall under HIPAA, and data from EU users falls under GDPR.

How to build for interoperability

These steps help device and software teams design interoperability in rather than add it later.

  1. Map every interface. List each external connection your product will have, from Bluetooth links to cloud APIs, and its purpose, users, and risks, following FDA’s six design considerations.
  2. Choose standards by layer. Use Bluetooth SIG services or IEEE 11073 at the device level, and HL7 FHIR with LOINC codes at the EHR level, before writing any custom code.
  3. Write a versioned interface specification. Document data formats, timing, error handling, and pairing, and plan how you will share them with partners, as required by ACE pump and iAGC special controls.
  4. Design a modular architecture. Separate device communication, algorithms, data storage, and user interface so you can add partners without rebuilding. See component architecture for SaMD and the role of software development kits.
  5. Build security in. Authenticate every connection, encrypt data in transit and at rest, maintain a software bill of materials, and plan for post-market vulnerability management.
  6. Validate the system, not just the device. Test every supported combination, including failure cases such as lost connections and out-of-range data.
  7. Agree on postmarket responsibilities. Decide in writing who handles complaints, adverse event reports, and updates when a problem crosses company lines.
  8. Plan for EHR delivery. Map your summary data to the HL7 FHIR CGM Implementation Guide so clinicians can see it in their own systems.

When several companies are involved, a neutral partner can coordinate shared specifications, integration testing, and regulatory alignment, so no single company’s priorities slow the others.

Frequently asked questions

What is diabetes device interoperability?

It is the ability of glucose sensors, insulin pumps, dosing algorithms, apps, and health record systems to exchange data and use it safely. It lets components from different companies work together in automated insulin delivery systems, and lets device data reach clinicians in the EHR.

Which standards are used for CGM and insulin pump data?

At the device level, the main standards are the Bluetooth SIG Continuous Glucose Monitoring, Glucose, and Insulin Delivery services, and the IEEE 11073 personal health device standards. For sending CGM data to the EHR, the HL7 FHIR CGM Implementation Guide and LOINC codes define the format.

What does FDA require for interoperable medical devices?

FDA’s 2017 guidance asks manufacturers to address each electronic interface’s purpose, users, risks, verification and validation, labeling, and use of standards. For diabetes components, special controls for ACE pumps and iAGCs also require validated interface specifications, secure pairing, reliable data transmission, and a process for sharing specifications with partners.

How does CGM data get into the EHR?

Typically, a CGM app or cloud platform sends summary reports and metrics to the EHR through a FHIR interface. The HL7 FHIR CGM Implementation Guide, published in September 2025, standardizes that exchange, building on the Diabetes Technology Society’s iCoDE consensus standards and LOINC codes for CGM metrics.

What is the HL7 FHIR CGM Implementation Guide?

It is an HL7 International standard, published as STU 1 in September 2025, for sharing continuous glucose monitoring data. It defines how to exchange CGM summary reports, metrics such as time in range and glucose management indicators, and individual sensor readings between apps, platforms, and EHRs.

Build interoperable diabetes software with Sequenex

Interoperability now decides which diabetes products reach users and clinicians. Building it in from the first requirement is far easier than retrofitting it after a partner asks.

Sequenex helps device makers and their partners define shared interface specifications, build modular software, and validate the combined system. See our biosensor and CGM software development services, or contact us to discuss your integration.

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