COMPLIANCE ROADMAP

Critical compliance dates

Plan your implementation strategy with these key milestones and deadlines. All dates are mandatory for impacted payers.

Rule Published

Final Rule Published

CMS published the Interoperability and Prior Authorization Final Rule (CMS-0057-F), establishing comprehensive requirements for FHIR API implementation and prior authorization reform.

  • Final rule text released
  • Implementation specifications detailed
  • Technical standards defined
  • Compliance timeline established
JAN 17 2024
Published
Operational Requirements

Prior Authorization Timeframes Begin

Decision timeframes for prior authorization requests take effect. Payers must comply with new maximum response times and transparency requirements for all authorization decisions.

  • 72 hours for urgent requests
  • 7 days for standard requests
  • All denials must include specific reasons
  • Electronic notification to patients and providers
  • Patient Access API metrics reporting begins
JAN 1 2026
Active
Public Reporting

First Public Metrics Due

Payers must publicly post their first set of prior authorization metrics and Patient Access API usage data. Annual reporting required thereafter for transparency and accountability.

  • Prior authorization approval/denial rates
  • Average decision timeframes
  • Volume of requests by service type
  • Patient Access API usage statistics
  • Post publicly on payer website
MAR 31 2026
84 Days
Full API Compliance

All FHIR APIs Must Be Live

Final compliance deadline for all five FHIR APIs. All impacted payers must have fully operational APIs meeting all technical and functional requirements.

  • Patient Access API (enhanced with prior auth)
  • Provider Access API (new)
  • Payer-to-Payer API (new)
  • Prior Authorization API (new)
  • Provider Directory API (new)
  • MIPS eligible clinicians begin ePA attestation
JAN 1 2027
360 Days