Five Key Signals from the CMS‑0057‑F WEDI Survey

Health plans are firmly focused on meeting the requirements of the Centers for Medicare & Medicaid Services Interoperability and Prior Authorization Final Rule (CMS‑0057‑F). But the path to readiness is far from uniform. Organizations are moving at different speeds, with different levels of confidence and that variability shows up clearly in the latest Workgroup for Electronic Data Interchange (WEDI) survey. It also mirrors what I hear consistently in conversations across the market.

Rather than rehashing the topline results, I want to focus on what the data signals beneath the surface: where execution risk is rising, how operational maturity is taking shape, and where many organizations may be underestimating the work still ahead.

Based on the latest WEDI findings, here are the five things that stood out to me.

1. Momentum is real, but readiness is still uneven

Only 16% of payers expect to be 75–100% complete by the January 1, 2027 deadline, up slightly from 12% in Oct 2025.

One of the most encouraging signals in the latest WEDI survey is that fewer payers report having not started their CMS‑0057‑F work. That’s meaningful progress compared to earlier waves, and it suggests the industry has largely moved past awareness and intent. At the same time, the data makes clear that readiness remains uneven.

Some organizations are well into execution, while others are still early in their journey. From my perspective, that gap matters because CMS‑0057‑F is not something teams can sprint through at the last minute. In practice, interoperability work becomes more interconnected over time; spanning architecture, governance, security, and partner coordination. As a result, far less progress has been made on the broader network strategy, creating a critical re‑engagement moment to address connectivity at scale.

The later organizations begin, the more complexity they encounter at once, rather than in manageable phases. As the WEDI results show momentum building, they also reinforce a reality I’ve seen repeatedly: starting is important, but how and when organizations sequence execution ultimately determines how steep the climb becomes. There are ways to flatten the slope; they require disciplined prioritization or thoughtful vendor selection to offload time-consuming technical tasks so health plans can focus on strategic progress. 

2. Patient Access API progress is steady but far from complete

35% of payers estimate they are 25% or less complete implementing the Patient Access API, down from 66% (Oct ’25).*

WEDI’s results show that Patient Access API implementation is still very much a work in progress. That stands out because Patient Access is often treated as the “known” requirement, the one teams feel most comfortable with. But that confidence can be misleading.

Patient Access was the first time plans had to stand up and manage a FHIR store, a data lake organized by categories of information you can call by name, resources like “Medications”. Many teams moved quickly in 2021–2022 just to meet the deadline. And in a lot of cases, those implementations checked the compliance box, but weren’t built to be used, scaled, or expanded. Moreover, most Patient Access APIs saw little to no real world adoption. The APIs and FHIR stores built to comply with CMS-9115 weren’t put through their paces to any real extent. 

And that’s where things get tricky. 

By expanding Patient Access to include prior authorization data and adding new APIs, CMS‑0057‑F is exposing gaps in data structure, workflow integration, and overall data reliability.

For many organizations, moving forward now means going back: reworking or undoing decisions made a few years ago before they can operationalize the data, in new ways, at scale. That adds time, complexity, and a very real dependency. The bottom line: how well Patient Access was built the first time will directly impact how smoothly plans can execute on CMS-0057-F. 

3. Cost estimates are rising as work becomes more concrete

The share of payers projecting costs above $5 million increased from 15% to 25%, reflecting a clearer understanding of the full scope of CMS‑0057 requirements.*

Another notable shift in the latest survey is how organizations are estimating the cost of compliance. As implementation moves from planning into build and testing, more respondents are reporting higher expected investments. That aligns closely with what I see in practice. 

Early planning often centers on building APIs, but costs rise quickly once organizations begin creating individual connections. Each payer, provider, delegated partner, or trading partner connection requires its own policy alignment, workflow setup, security controls, testing, and ongoing monitoring. Those costs don’t stop after go‑live. They continue over time. 

As the number of connections grows, organizations that manage connectivity on their own take on more operational responsibility with each new relationship. However, a secure connectivity network helps change that equation by reducing the need to build and maintain individual connections.

CMS‑0057‑F is not a one‑time delivery effort. It introduces ongoing operational exposure. The survey reinforces a key reality: this is a cross‑enterprise initiative, and cost expectations adjust once that becomes clear. 

 4. Implementation is advancing faster than operational readiness

Top three payer-reported implementation challenges*:

Sufficient funding

Digitizing prior authorization policies

Delegated third parties facing challenges connecting with different systems

What stood out most clearly to me in the WEDI data is that payers remain focused on execution‑ and financially driven hurdles. While necessary to stand capabilities up across a fragmented ecosystem, these challenges alone do not determine long‑term success. The greater imperative is coordinating workflow changes across internal teams, establishing data governance and accountability, defining clear success metrics, and preparing to ingest, standardize, and operationalize new data streams. These are the levers that will determine whether plans simply meet regulatory requirements or adapt, scale, and capture meaningful value from their CMS‑0057‑F investments.

5. The execution gap is becoming the defining risk

Provider-side readiness issues*:

One-third of providers have yet to start implementation

Only 13% of payers report being at or near completion

Taken together, the WEDI findings point to what I see as the central risk facing both health plans and providers right now: the execution gap. Many organizations understand the rule. Many are building required APIs. But fewer are confident that what they’re building will scale, be adopted, and reliably ingest, standardize, and use the new data in real‑world conditions.

This is where CMS‑0057‑F efforts are most likely to break down. Execution stalls when governance is unclear, when delegated partners aren’t fully integrated, when workflows are redesigned in isolation, or when funding is treated as a one‑time exercise instead of a sustained commitment. The survey doesn’t just measure readiness; it highlights where these cracks are starting to form.

What this means going forward

WEDI’s latest survey shows health plans have entered a new phase of CMS‑0057‑F, shifting from regulatory interpretation to navigating how to make interoperability work consistently across teams, workflows, and partner ecosystems.

If you’re looking to move beyond compliance and turn CMS‑0057‑F into durable, operational interoperability, download the Blueprint to understand what it takes to execute for real-world API usability, not just comply.

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About the Author

Chris Kenyon leads Clinical Solutions at Availity, partnering with health plans to advance interoperability and create business value by amplifying the exchange and application of clinical data across networks and enterprises. He brings deep payer-side experience, including roles in enterprise strategy and value-based program design at CVS Health | Aetna, along with P&L responsibility for clinically grounded utilization management programs at national scale. Today, Chris works closely with health plan customers to modernize clinical connectivity, data optimization, and CMS-0057-F compliance strategies.