The industry has been rightly focused on implementing the technical infrastructure required to support new health data exchange and prior authorization regulations, but CMS-0057-F makes it clear that compliance success depends on more than FHIR APIs alone. Specifically, members must understand what information may be shared, who can receive it, how sharing may benefit their care, and how they can manage their preferences.
Let’s take a closer look at what CMS 57-F says about member education, what member experience looks like, and which resources and solutions are available to meet the January 1, 2027 compliance milestone and establish a foundation for annual member education efforts.
There are significant member education and outreach requirements tied to Provider Access and Payer-to-Payer APIs, and educational resources must remain easily accessible on public websites and be communicated annually at key enrollment-related milestones.
Provider Access API: Health plans must educate members about the benefits of sharing information with providers, explain the member's right to opt out, and provide clear instructions for exercising or changing that preference.
Payer-to-Payer API: Plans must explain the benefits of exchanging information with previous or concurrent payers, obtain an affirmative opt-in decision, and support future withdrawal of consent.
CMS expects these communications to be delivered through the member engagement channels health plans already use including email, direct mail, secure digital communications, text messaging, and phone outreach. This shifts interoperability efforts into a member engagement strategy, where simply posting the information online will not suffice.
Plans must ensure members receive clear, plain-language education through trusted communication channels at the right moments throughout the member journey. As compliance deadlines approach, health plans should evaluate whether their existing outreach infrastructure can support consistent education and ongoing awareness around data-sharing preferences.
They should also be mindful of evolving communication regulations. The FCC's Telephone Consumer Protection Act (TCPA) global opt-out requirements (scheduled to take effect January 31, 2027) reinforce the importance of implementing the systems necessary to support global opt-out both internally and across partners and vendors. As member communications expand to support interoperability education, plans should ensure outreach strategies align with applicable communication and consent requirements.
Start with understandable explanations of how data sharing works, with clear answers to fundamental questions including what information is being shared, who will receive it, how sharing can support care coordination, and which privacy and security measures are in place.
For Provider Access, members must understand their ability to opt out and their right to change that preference later. For Payer-to-Payer exchange, they must be able to make an informed opt-in decision and withdraw consent in the future if desired. Consent should not be viewed as a one-time transaction as members need accessible ways to revisit and update their preferences over time. Successful outreach strategies will leverage multiple communication channels to reinforce the same educational messages while guiding members toward preference-setting tools when appropriate.
Preparing for CMS-0057-F requires both technical interoperability capabilities and effective member engagement strategies. Cotiviti is helping our clients prepare for compliance using solutions and strategies aligned to specific CMS-00057-F requirements, including but not limited to:
These solutions help address secure data exchange while helping members understand and manage their role in that exchange. Organizations that combine interoperable infrastructure with effective member education and consent management will be better positioned to support meaningful participation in data-sharing programs and realize the broader promise of nationwide interoperability.
To discuss your CMS 57-F readiness or interoperability concerns, request a conversation or reach out to your primary Cotiviti representative.