⚠ CMS Deadline: March 31, 2026
CMS Interoperability & Prior Authorization Rule

Prior Auth
Immediate. Not 72 Hours.

CMS mandates prior authorization decisions within 72 hours. Orchestral's HAL Platform makes them immediate — seconds, not days. One API. Full compliance. Zero rebuilding.

72 hrs
CMS requirement (urgent)
<10 sec
HAL Platform decision
4
FHIR APIs required by CMS
1 API
HAL covers all four
⚡ Book a Walkthrough
CMS-0057-F
What the Rule Requires
The CMS Interoperability & Prior Authorization Final Rule replaces slow, manual PA processes with FHIR-based, automated workflows. Non-compliance means civil monetary penalties and public disclosure starting 2026.
🏦

Payers Must…

Build and maintain four FHIR APIs: patient access, provider access, prior authorization, and payer-to-payer
Return PA decisions within 72 hours (urgent) or 7 calendar days (standard)
Provide specific, clinically-grounded denial reasons — not generic codes
Report Patient Access API usage metrics to CMS annually
Publish PA performance metrics publicly (first due March 31, 2026)
🏥

Providers Must…

Submit at least one electronic PA request per year (MIPS requirement)
Integrate EHR systems with FHIR-based PA workflows — specifically the Da Vinci IGs: CRD, DTR, and PAS
Package clinical evidence in structured FHIR formats for electronic submission
The Opportunity
72h → <10s

CMS sets a floor. HAL blows past it.

Every other compliant solution meets the 72-hour minimum. HAL Platform delivers immediate prior authorization — decisions in seconds, not hours or days. That's not just compliance. That's a competitive advantage your payer clients can market.

HAL Platform
One API. Immediate PA. Full Compliance.
Orchestral's Health Automation Layer (HAL) is a single API endpoint that handles everything CMS requires — and delivers decisions that are immediate, specific, and auditable. No rebuilding required.
⚡

Immediate Decisions

Where CMS mandates 72 hours, HAL responds in under 10 seconds. Payer policy is matched against clinical evidence in real time — returning an immediate, auditable decision before the clinician leaves the screen.

🔌

FHIR-Native, All Four APIs

HAL builds and operates all four FHIR APIs required by CMS — Patient Access, Provider Access, Prior Authorization, and Payer-to-Payer. Fully conformant with HL7 FHIR R4 and Da Vinci implementation guides.

⚙️

Embedded Policy Engine

Payer authorisation rules are loaded directly into HAL. Think of it as embedding the payer's rulebook inside the system — so when a PA arrives, it's matched against policy instantly, consistently, and with a complete audit trail every time.

📋

Specific Denial Reasons

HAL returns clinically-grounded denial reasons tied to the exact policy criteria that weren't met — never generic error codes. CMS requires this. HAL makes it automatic.

📊

Auto-Generated Reporting

Built-in dashboards capture PA volume, decision rates, turnaround times, and denial reasons. CMS annual metrics submissions and public disclosure reports are generated automatically.

🛡️

Plug In, Don't Replace

HAL sits alongside your existing claims and MMIS systems as a compliance layer. One API integration — no rip-and-replace, no multi-year transformation programme required.

HAL in Your Architecture

🏥
Provider EHR
CRD / DTR / PAS
→
🌐
HIE / Network
FHIR Exchange
→
🧠
HAL Platform
FHIR · Policy · Audit
→
⚖️
Payer Policy
Auth Rules
→
✅
PA Decision
<10 seconds
A New Way to Do Business
Where Clinical Reality Meets Payer Policy
The HIE becomes a neutral broker — not a managed service, not a middleman. Clinical data flows in from one side, payer policy flows in from the other. HAL matches them instantly, inside the HIE, and the decision comes back before anyone picks up a phone.
What happens inside the HIE
Clinical Data In
🏥
Clinical EHR
Patient record, diagnosis, history
🩺
Treatment Request
Procedure, urgency, clinical notes
📋
Supporting Evidence
Prior tests, imaging, referrals
clinical
⟶
🧠
HAL
inside the HIE
⚡ matching in real time
policy
⟵
↓
✅ Immediate Decision
<10 seconds · with reason
Payer Policy In
📜
Coverage Policy
What the plan covers, and when
⚖️
Auth Rules
Criteria for approval or denial
🏛
Clinical Guidelines
Evidence-based treatment standards
🏥
Clinicians focus on care
No forms, no phone queues, no fax. The EHR handles it — invisibly.
🌐
HIE becomes the marketplace
A neutral broker where clinical evidence and payer policy meet — automatically.
💼
Payers set rules once
Policies are loaded into HAL. Every PA is evaluated consistently, immediately, at scale.

❌ The Old Way

Providers fax or phone each payer. Payer staff manually review clinical documents. Decisions take days. Everyone pays the cost in time, admin, and delayed care.

🔴 Each provider integrates separately with every payer
🔴 Payers build four FHIR APIs from scratch, independently
🔴 Inconsistent rules applied differently each time
🔴 Providers face a different system for every payer
🔴 PA takes days — care is delayed

✅ The HIE Model with HAL

The HIE becomes the single point where clinical data and payer policy are matched in real time. Connect once. Work with everyone. Decisions in seconds.

🟢 Providers connect once to the HIE — done
🟢 Payers load their policy into HAL — done
🟢 HAL matches clinical evidence to policy automatically
🟢 HIE earns revenue as the neutral broker
🟢 Immediate decisions — every time, for everyone

The Network Effect — One Connection, Every Counterparty

🏥 Hospital EHR
🩺 Clinic System
💊 Pharmacy
🖥 Telehealth
Clinical Data
⟶
🌐
HIE + HAL
Neutral Broker
Clinical meets Policy · Instant
Policy & Rules
⟵
💼 Medicaid Plan
🏛 Medicare Adv.
🏢 Commercial Plan
⚕️ Self-Insured
1×
Connection
Providers connect to the HIE once — instantly reach every payer on the network
100%
CMS Compliance
All four required FHIR APIs handled by HAL for every connected payer
New $
HIE Revenue
HIEs earn as the neutral broker — a new line of business, not a cost centre
Interactive Demo
A PA Request — Start to Finish
Walk through a real prior authorization: from a clinician ordering a scan, to an immediate decision returned through the HIE. Press Next Step or Auto-Play.
👨‍⚕️
Clinician
/ EHR
▶
📦
FHIR PAS
Bundle
▶
🌐
HIE
Hub
▶
🧠
H
HAL
Platform
▶
⚖️
Policy
Matching
▶
✅
Immediate
Decision
1
PA Request Initiated
Dr. Chen orders an MRI for a patient with suspected lumbar stenosis. The EHR detects — automatically — that prior authorization is required under the patient's Medicaid plan. No forms. No phone calls.
Patient: PT-2847-MC Service: MRI Lumbar Spine (CPT 72148) Diagnosis: M47.816 — Spondylosis, lumbar region Urgency: Standard | CMS Deadline: 7 calendar days
⟶ HAL will return a decision before Dr. Chen closes the tab.
🏢 Tailored for Gainwell Technologies
HAL + Gainwell: Immediate PA at Government Scale
Gainwell powers healthcare programs for millions of Medicaid and Medicare beneficiaries. HAL Platform plugs directly into Gainwell's infrastructure to deliver CMS-compliant, immediate prior authorization at the scale government programs demand.
🏛

Government Program Ready

HAL is pre-configured for Medicaid and Medicare PA requirements. Payer policy libraries include state-specific Medicaid authorisation criteria, updated continuously by Orchestral's clinical team.

🔧

MMIS Integration

HAL connects directly to Gainwell's MMIS and claims adjudication systems via FHIR. No rearchitecting — HAL operates as a compliance layer alongside your existing infrastructure.

📈

Scale to Millions

Architected for high-volume government programs. HAL processes millions of PA transactions with 99.9% uptime SLAs, full redundancy, and HIPAA-compliant data handling throughout.

📊

Auto-Compliance Reporting

HAL generates the PA performance metrics CMS requires payers to publish annually — correctly formatted for submission and public disclosure, from day one.

CMS Compliance Checklist — Gainwell

🔌

Prior Authorization FHIR API (PAS)

Electronic PA submission and response using FHIR PAS IG — the Da Vinci standard

HAL Covers
👤

Patient Access API

Member access to their own coverage, claims and PA status data via FHIR

HAL Covers
🏥

Provider Access API

Provider access to member coverage information and PA history at point of care

HAL Covers
🔄

Payer-to-Payer API

Exchange of member data when beneficiaries transition between plans or programs

HAL Covers
⚡

Immediate PA Decisions (<10 sec vs. 72 hr mandate)

Payer policy matched to clinical data in real time — decisions returned immediately with full audit trail

HAL Exceeds
📋

Annual Public PA Metrics — first due March 31, 2026

HAL auto-generates and formats required public disclosures for CMS submission

HAL Covers
orchestral.co · CMS PA Compliance
⚠ CMS Deadline: March 31, 2026

Immediate Prior Authorization.
Full CMS Compliance. One API.

CMS now mandates prior authorization decisions within 72 hours. Orchestral's HAL Platform makes them immediate — under 10 seconds, end to end. A single API integration covers all four FHIR APIs CMS requires, embeds payer clinical rules (CQL) for real-time decisions, and auto-generates annual compliance reporting. Works for payers, providers, and — critically — Health Information Exchanges acting as the compliance hub between them.

<10s
HAL decision time
72 hrs
CMS minimum
4 APIs
Required by CMS
1 API
HAL covers all 4
Mar 31
First metrics due

What HAL Delivers

  • Immediate PA decisions — seconds, not hours
  • All 4 required FHIR APIs (Patient, Provider, PA, P2P)
  • Embedded policy engine — payer rules pre-loaded
  • Specific, clinically-grounded denial reasons
  • Auto-generated CMS annual metrics reports
  • Full audit trail on every decision

The HIE Opportunity

  • HIE deploys HAL as a shared compliance hub
  • Payers connect once — immediately compliant
  • Providers use one standard API across all payers
  • Eliminates the N×M direct-integration problem
  • New HIE revenue model: compliance-as-a-service
  • Immediate PA for every participant in the network

How a PA Flows

  • Clinician submits PA — EHR creates FHIR PAS Bundle
  • Bundle routes to HIE → HAL validates & enriches
  • Payer policy matched to clinical evidence in real time
  • Immediate decision + specific reason returned to EHR
  • CMS-compliant audit trail logged automatically

Ideal For

  • HIEs — become the regional compliance hub
  • Payers (Medicaid, Medicare Advantage, commercial)
  • Government health IT (Gainwell, MMIS vendors)
  • Healthcare networks needing immediate PA

See Immediate PA in under 30 minutes

We'll map HAL to your architecture and show a live PA decision.

Book a Walkthrough →