⚠ 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
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 →