Comment on CMS-2026-2279-0001
David RochaSupportOther
Summary: The commenter advocates for CMS to accelerate the adoption of standards-based APIs (specifically FHIR) and computable contracts for Medicaid managed care reporting. They argue that current manual processes involving PDFs and spreadsheets at the subcontractual and delegated layers hinder interoperability and call for regulatory requirements to ensure real-time, standardized data exchange.
The entities at the subcontractual relationships and delegated layer exchanging electronic PDFs, electronic faxes, spreadsheets, CSVs, image files are not interoperable, especially when the corporate parent organizations are claiming standards-based interoperability.
The hidden subcontracting layer of subcontractual relationships and delegation shall not be allowed to remain analog while the parent organizations claim digital interoperable compliance.
See attached file for more recommendations.