```
4
Mandated FHIR APIs
365
Payer Organizations
$16B+
Provider Savings (10yr)
220M
Hours of Burden Cut
~900
Public Comments
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What Is CMS-0057-F?

CMS-0057-F is a federal final rule published by the Centers for Medicare & Medicaid Services (CMS) in January 2024. Its full title is "Advancing Interoperability and Improving Prior Authorization Processes" and it amends 42 CFR Parts 422, 431, 435, 438, 440, 457, and 45 CFR Part 156 (RIN 0938-AU87).

The rule builds on the 2020 CMS Interoperability and Patient Access final rule (85 FR 25510) by establishing new API mandates, accelerating prior authorization decision timelines, and requiring public transparency reporting. CMS received nearly 900 public comments on the proposed rule and finalized with modifications in response.

Who Must Comply?

CMS identifies 365 parent payer organizations spanning six categories of "impacted payers":

Medicare Advantage Organizations State Medicaid FFS Programs Medicaid Managed Care Plans (MCOs, PIHPs, PAHPs) State CHIP FFS Programs CHIP Managed Care Entities QHP Issuers on FFEs

Excluded: Stand-alone dental plan (SADP) issuers, FF-SHOP-only issuers, and State-based Exchange (SBE/SBE-FP) issuers. Medicare FFS is not directly mandated but CMS has stated its intent to voluntarily comply.

The Four Mandated APIs

APIPurposeKey DataDeadline
Patient Access API Patient-facing data access via third-party apps Claims, USCDI clinical data, prior auth info, lab results, cost-sharing Jan 2027 (PA data enhancement)
Provider Access API Provider access to patient data held by payers Claims & encounters (no remittances), USCDI, prior auth info Jan 2027
Payer-to-Payer API Automated data exchange when patients change plans 5 years of claims, USCDI, prior auth info; quarterly concurrent exchange Jan 2027
Prior Authorization API Electronic PA requirements discovery, docs, and submission PA requirement check, documentation rules, request submission & decision Jan 2027

Prior Authorization Process Reforms (2026)

⏱ Mandated Response Times

72 hours for urgent/expedited PA requests and 7 calendar days for standard requests. Applies to all impacted payers except QHP issuers on the FFEs.

βœ— Specific Denial Reasons

Payers must include a specific reason in every PA denial notice sent to providers. Generic or boilerplate denial language is no longer compliant.

πŸ“Š Public Metrics Reporting

All impacted payers must publicly report PA approval/denial rates, response times, and related metrics β€” creating unprecedented transparency in the PA process.

πŸ“ˆ API Usage Reporting to CMS

Payers must report Patient Access API utilization metrics to CMS annually, including the number of unique patients accessing data through third-party apps.

Technical Standards Required

πŸ”₯ HL7 FHIR R4.0.1

Base interoperability standard for all four APIs. Codified at 45 CFR 170.215(a)(1).

πŸ‡ΊπŸ‡Έ US Core IG STU 3.1.1

FHIR profiling for US healthcare data. Expires Jan 1, 2026. 45 CFR 170.215(b)(1)(i).

πŸ” SMART App Launch 1.0.0

OAuth 2.0-based authorization framework for patient-facing apps. 45 CFR 170.215(c)(1).

πŸ“¦ Bulk Data Access v1.0.0

FHIR Bulk Data (Flat FHIR) for large-scale data retrieval. 45 CFR 170.215(d)(1).

πŸͺͺ OpenID Connect Core 1.0

Identity layer for patient authentication. 45 CFR 170.215(e)(1).

πŸ“‹ USCDI v1 β†’ v3

Content standard at 45 CFR 170.213. USCDI v1 expires Jan 2026; auto-updates as ONC adopts new versions.

Projected Impact

πŸ’° $16 Billion+ in Savings

CMS estimates provider burden will be reduced by at least $16 billion over 10 years through streamlined PA processes and automated data exchange. Savings accrue to clerical, nursing, and clinical provider staff.

⏰ 220 Million Hours Saved

Total provider burden reduction of at least 220 million hours over 10 years β€” time currently spent on phone-based PA submissions, fax chasing, and manual data retrieval from payer portals.

πŸ₯ EHR Adoption Baseline

The rule leverages existing EHR infrastructure: as of 2021, 78% of office-based physicians and 96% of non-federal acute care hospitals had adopted certified EHR technology, and over $38 billion in incentives had been paid through Promoting Interoperability programs.

βš–οΈ Significant Regulatory Action

OMB/OIRA determined the rule has an annual effect exceeding $200 million, classifying it as a significant regulatory action and a major rule under the Congressional Review Act.

What's Excluded?

Drugs are out of scope. The prior authorization API and process requirements do not apply to drugs of any type β€” prescription, self-administered, provider-administered, pharmacy-dispensed, or hospital-administered. Drug PA involves separate processes, standards, and regulatory frameworks. However, prescription drug claims data is still shared through the Patient Access API as part of the patient's record.

Key Regulatory References

πŸ“„ This Rule

CMS-0057-F (RIN 0938-AU87). Amends 42 CFR Parts 422, 431, 435, 438, 440, 457 and 45 CFR Part 156.

πŸ“„ Proposed Rule

Published December 13, 2022 in the Federal Register (87 FR 76238).

πŸ“„ 2020 Foundation Rule

CMS Interoperability and Patient Access final rule (85 FR 25510, May 1, 2020). Established the original Patient Access API mandate.

πŸ“„ ONC HTI-1 Final Rule

Published January 9, 2024 (89 FR 1192). Reorganized 45 CFR 170.215 technical standards structure referenced by CMS-0057-F.

Read the FAQ β†’ ← Back to Overview
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