CMS-10553 (Medicaid Managed Care Quality including Supporting Regulations)

The commenter supports the proposed action and urges CMS and the ONC to classify all delegated and downstream entities as first-tier FHIR execution actors. They argue that mapping these subcontractual relationships is necessary to ensure a completely connected experience and consistent semantic interoperability across the healthcare ecosystem.

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 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.

The commenter supports the proposed action but argues that it should be expanded to include subcontractual relationships and delegation. They specifically request that CMS classify these relationships as first-tier FHIR execution actors.