Comment on CMS-2026-2279-0001
David RochaSupportIndividual
Summary: The commenter supports the proposed action and urges CMS to expand the scope of FHIR execution requirements to include all subcontractual relationships and delegated downstream entities. They specifically request updates to 42 CFR 438.230 to ensure that all implementation partners and contracted entities are required to use specific FHIR Implementation Guides (IGs) to support executable APIs for Medicaid beneficiaries.
Entities which support Subcontractual relationships and delegation shall be required to use all of the latest Da Vinci FHIR IGs, including:
•PDex: Payer Data Exchange
•CDex: Clinical Data Exchange
•ATR: Member Attribution List
•Notifications
•CRD: Coverage Requirements Discovery
•DTR: Documentation Templates and Rules
•PAS: Prior Authorization Support
•PCT: Patient Cost Transparency
•VBPR: Value-Based Performance Reporting
•DEQM/GIC: Data Exchange for Quality Measures/Gaps In Care
•RA: Risk Adjustment
•HRex: Health Record Exchange
•Common CQL Artifacts for FHIR
•Postable Remittance
•Formulary
•Plan Net/Directory
Entities which support Subcontractual relationships and delegation entities shall be required to use all of the latest CARIN Alliance FHIR IGs, including:
•CARIN IG for Blue Button
•CARIN IG for Digital Insurance Card
•CARIN Patient-facing Real Time Pharmacy Benefit Check
Entities which support Subcontractual relationships and delegated entities be required to use all of the latest Gravity Project FHIR IGs, including the SDOH Clinical Care FHIR IG.
In this manner, Subcontractual relationships and delegation entities will use the latest FHIR IGs at this lower layer that is lower than delegated and downstream entities.
The Subcontractual relationships and delegation layer shall support executable FHIR and the latest FHIR IGs, as well as delegated managed care functions at this lower layer, including but not limited to:
•Subcontractual relationships and delegation related utilization management
•Subcontractual relationships and delegation related risk adjustment
•Subcontractual relationships and delegation related quality reporting
•Subcontractual relationships and delegation related credentialing
•Subcontractual relationships and delegation related care coordination