Why Most Organizations Are Already Behind on CMS-0057-F

And Why Epic’s Unified Authorization Table Is Emerging as the Backbone of Compliance Readiness

Written by: Melanie Cameron

Imagine it is early 2027.

 Your organization’s interoperability program is technically complete. The FHIR-based prior-authorization API is live, and your compliance reports check every box. Yet within operations, the friction remains. Utilization Management and Claims teams are still reconciling decisions manually. Turnaround times are edging toward CMS limits. Providers continue to escalate because, despite the API, the experience feels no faster or clearer than before.

This is the quiet risk across much of the industry: regulatory compliance achieved without operational transformation.

The Challenge Behind CMS-0057-F

The CMS Interoperability and Prior Authorization Final Rule (CMS-0057-F), finalized in 2024, represents one of the most sweeping regulatory shifts in health-plan administration in decades. It requires Medicare Advantage, Medicaid, CHIP, and Marketplace plans to implement standardized, FHIR-based interfaces for patient access, provider access, payer-to-payer exchange, and prior authorization by January 1, 2027.

Equally significant, the rule accelerates decision timeframes beginning in 2026—72 hours for urgent and seven days for standard requests—and mandates public reporting of approval rates, turnaround times, and denial trends.

While these goals support transparency and member experience, the operational impact is profound. The policy presumes that every impacted organization has a unified, real-time view of authorization data spanning Utilization Management, Claims, and Provider systems. For most, that infrastructure does not yet exist.

The real challenge, therefore, is not standing up a FHIR API—it is re-engineering the data foundation that powers those APIs so that authorization decisions are accurate, traceable, and synchronized across departments.

Epic’s Role: From Compliance Platform to Integration Backbone

Among major technology ecosystems, Epic is uniquely positioned to meet this moment. Its Tapestry Payer Suite already consolidates medical management, claims, and provider operations under one architecture. CMS-0057-F exposes less a gap in Epic itself and more a readiness gap in how organizations have historically implemented and governed their authorization data.

Epic’s response, the Unified Authorization Table (UAT), is designed to close that gap. The UAT centralizes authorization records across lines of business, creating a single source of truth that supports both internal operations and FHIR-based interoperability. It provides the structural layer that allows organizations to:

  • Align authorization logic across Utilization Management and Claims
  • Ensure real-time data consistency for API exposure and reporting
  • Simplify compliance auditing and metric tracking
  • Improve transparency for members and providers through accurate status visibility

Rather than bolting on new integrations, the UAT transforms authorization from a transactional workflow into a cohesive, data-driven process that underpins compliance, analytics, and experience.

Industry Readiness and the Growing Gap

Despite clear regulatory milestones, most organizations remain behind. Surveys from AHIP, WEDI, and Deloitte in 2025 indicate that fewer than one-third have begun comprehensive workflow redesign or end-to-end data mapping. Many efforts remain narrowly focused on API connectivity rather than on building the unified data structures that give those APIs purpose.

Common barriers include:

  • Resource competition from other modernization programs such as claims migration or interoperability upgrades
  • Distributed ownership of authorization data across UM, IT, and operations teams
  • Limited workforce capacity, especially among Epic-certified UM and Claims professionals

This combination of factors has created a widening readiness divide. Early movers are using Unified Authorization initiatives to create durable enterprise governance models, while late adopters risk layering technical compliance over fragmented processes.

Turning Compliance Into Strategy

For organizations running Epic, the Unified Authorization Table offers a pathway not just to compliance, but to long-term operational modernization. By establishing a unified authorization foundation, they can:

  • Reduce administrative overhead and manual reconciliation
  • Improve consistency and transparency of decision logic
  • Generate reliable metrics for CMS reporting and internal oversight
  • Enable automation and AI-driven analytics across the enterprise

In this way, Epic becomes not merely the system of record but the strategic infrastructure for regulatory resilience. Organizations adopting the UAT are positioning themselves to meet CMS-0057-F with confidence while simultaneously strengthening member experience and operational agility.

The Moment of Decision

As January 2027 approaches, the question is no longer whether an organization can technically enable a FHIR API. The defining factor will be whether that API reflects a unified, trustworthy, and transparent authorization dataset.

Epic’s Unified Authorization Table provides that foundation. CMS has raised the bar for transparency and timeliness; Epic has built the framework to meet it. The organizations that act now will not only comply with the regulation but also emerge with a scalable model for future interoperability mandates and a more connected, responsive system of care.

Assessing Your CMS-0057-F Readiness
For Epic-based health plans, CMS-0057-F compliance will ultimately be defined by the quality and governance of authorization data—not the existence of an API.

Canopii Collaborative works with payer organizations to evaluate Unified Authorization readiness across UM, Claims, and provider workflows, helping teams identify gaps early and align on a scalable path forward.

Learn more about our Epic payer advisory and staffing support here.

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