What do CMS interoperability and prior authorization rules require?
CMS interoperability rules require affected payers to expose health data through standards-based FHIR APIs. That generally includes Patient Access, Provider Access, and Payer-to-Payer APIs, plus prior authorization APIs and reporting that make utilization management decisions and status available programmatically. Meeting the rules is an engineering and operations program, not only a compliance exercise, because it depends on data availability, member matching, attribution, and consent.
- Map each requirement to a concrete capability, data source, system, and accountable owner.
- Confirm data availability and quality before committing to API delivery dates.
- Design member matching, attribution, and consent handling explicitly.
- Build testing and evidence collection into delivery so compliance reviews are straightforward.
