

This document is a checklist designed for payers to ensure compliance with the CMS Interoperability and Prior Authorization Final Rule (CMS-0057-F). The checklist outlines critical deadlines and requirements that payers must meet, including FHIR API implementation by January 1, 2027, and operational requirements by January 1, 2026. It details specific areas of focus such as prior authorization turnaround times, denial reason transparency, and patient access mechanisms. The checklist emphasizes the importance of assembling a cross-functional implementation team, selecting technology partners, and developing an internal education plan. Additionally, it includes public reporting requirements that begin on January 1, 2027, which necessitate the development of a reporting framework for various metrics related to prior authorization requests. The document serves as a practical guide for payers to monitor their progress and align their teams as they work towards compliance with the new regulations.