The CMS Mandated Shift to Data Transparency and Accountability
All U.S. Payers must publish their Prior Authorization (PA) metrics on their public websites by March 31, 2026, using data from Measurement Year (MY) 2025, as required under the CMS-0057-F Rule. The rule mandates health plans to execute a fundamental reset of their data and prior authorization processes, moving from static, manual reporting to real-time operational accountability and transparency.
Payers must ensure that all required prior authorization data from MY 2025, from provider EHRs, internal systems, and delegated entities, is consistently captured, validated, and reportable. This requires unified FHIR data management, and without it, Payers will risk non-compliance, penalties of up to $1,000 a day, and low member and provider satisfaction scores. Data transparency and interoperability at the level required by CMS-0057-F represent a new standard for the healthcare ecosystem. With less than six months remaining to ensure that all MY 2025 data is accurately captured and reportable, Payers can use this checklist below to assess their progress and identify any remaining gaps.
If your organization hasn’t started, or is stalled in its efforts, there is still time to meet the March 2026 milestone.
The CMS-0057-F Rule requires a complete transition from manual, paper-based or hybrid prior authorization workflows to electronic, FHIR®-enabled systems that integrate directly with provider EHRs. This shift is not minor. It requires implementing the four FHIR APIs, modernizing legacy data flows, and coordinating operations across the entire Payer network, integrating with all third-party systems and Provider EHRs. It also requires data transparency and public reporting. While several large payers are well underway, others remain early in the process and are facing predictable roadblocks.