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ARTICLE · 08 FEBRUARY 2024

CMS Issues Interoperability And Prior Authorization Final Rule

Crowell & Moring LLP
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On January 17, 2024, the Centers for Medicare & Medicaid Services (CMS) issued the Interoperability and Prior Authorization Final Rule (Final Rule), which establishes requirements applicable...

United StatesFood, Drugs, Healthcare, Life Sciences
Jodi G. Daniel
Jodi G. Daniel
Lidia Niecko-Najjum
Lidia Niecko-Najjum
Allison Kwon
Allison Kwon

On January 17, 2024, the Centers for Medicare & Medicaid Services (CMS) issued the Interoperability and Prior Authorization Final Rule (Final Rule), which establishes requirements applicable to certain impacted payers which are intended to improve the electronic exchange of health information and prior authorization processes. The application programming interface (API) requirements will take effect January 1, 2027, while the operational provisions will take effect January 1, 2026. CMS has issued a helpful slide deck summarizing the Final Rule.

We provide our key takeaways below, followed by a summary of the Final Rule's provisions.

Takeaways

  • While many payers are still focused on adoption of the 2020 interoperability requirements (the "2020 Requirements") and there is limited use of the APIs included in the 2020 Requirements, CMS is continuing to push payers to provide patients, providers, and other payers additional access to data via standardized, Health

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