November 5, 2020 CMS’ Interoperability & Patient Access Final Rule (CMS-9115-F) – Navigating Implementation and Compliance

The Centers for Medicare & Medicaid Services (CMS) issued a final rule in April of this year regarding interoperability and patient access to health data. The CMS Interoperability and Patient Access Final rule is designed to empower patients by giving them access to their health data when they need it and on any device or application of their choice. The rule further mandates the implementation of industry-wide technical standards such as Fast Healthcare Interoperability Resources (FHIR) Standards for APIs, secure authorization of third-party apps using the OAuth 2.0, OpenID Connect and Content and Vocabulary Standards.


According to

The Interoperability and Patient Access final rule (CMS-9115-F) delivers on the Administration’s promise to put patients first, giving them access to their health information when they need it most and in a way they can best use it. 

This Data includes:

  1. Through Patient API Access
    • Claims & Encounter Data
    • Clinical Data
    • Plan Coverage and Formularies
  2. Through Provider Directory API: Provides information specific to the practitioner and includes provider name, NPI, specialty, insurances accepted, hospital affiliations, gender, languages spoken by the practitioner, and locations at which the provider is available

To be compliant and to avoid penalties, CMS-regulated payers (excluding issuers offering only stand-alone dental plans (SADPs), Federally-facilitated Small Business Health Options Program (SHOP) plans and State-based Exchanges on the Federal platform (SBE-FPs)) must implement and maintain a secure, standards-based Patient Access API that allows patients to easily access certain health information.

This rule also requires Medicare Advantage (MA) organizations, Medicaid FFS programs, CHIP FFS programs, Medicaid managed care plans, and CHIP managed care entities to make provider directory information publicly available via a FHIR-based Provider Directory API.

The deadline for companies to implement the Patient Access API and Provider Directory API is July 1, 2021. Failure to comply on time may result in penalties. 


Here’s a few thing to consider if you’re still undecided on your compliance approach, or if you’ve run into challenges executing your existing plan:

  • Whether you’re buying or building, how prepared is your internal data for onboarding or interfacing with the required APIs? Is it defined according to HL7 FHIR R4 standards in order to ensure compliance and integration with APIs?
  • Have you accounted for the ramp-up time and various skill sets required for each stage of implementation?
  • Have you considered the availability of internal experts to support your compliance effort, and accounted for the impact to other planned projects?
  • Does your company have a strategy to remain agile and competitive in the post-compliance marketplace? 
  • Does your compliance plan set you up for success in responding to new opportunities and requirements after July 1?
  • Unexpected challenges and delays happen. Does your plan include the ability to surge support or support technical changes without derailing your compliance timeline?

This is all time bound, and the potential ripple effects of failing to plan and implement properly are significant. 


Topcoder is helping companies, from major Blue Cross Blue Shield providers to solution providers, build the assets and access the talent required for Compliance today. Wherever you are in your compliance journey, Topcoder has on-demand talent and access to the knowledge and resources to help. As 2020 draws to a close, Topcoder will be entering our 20th year. That’s nearly two decades of delivering technology outcomes for enterprise customers through our crowdsourcing platform.

  1. Breadth of talent in the community – Get immediate access to a large talent pool with niche skills that you can engage with on demand.There are over 400 tracked skills in the Topcoder community, including Python / C / C++ / Perl, SQL / NoSQL/ Hadoop, Machine Learning, Java, Javascript, Node.js, code, and Selenium testing.
  2. Start faster – The majority of enterprise projects on Topcoder go from contract signed to real work starting on the platform in under 5 days. Some work begins in under 24 hours. 
  3. Execute multiple tracks in parallel to speed delivery – Run multiple simultaneous work streams to deliver up to 3x faster. Use different skills for different projects or phases of your project. Individuals in the crowd are like hyper-specialists that can be brought on to your work on demand, the same way you’d stream a show.
  4. Pay for outcomes, not hours – Due to the structure of our business model for projects, you don’t have to worry about long-term costs, because every dollar is tied to an outcome.
  5. Guaranteed outcomes – Topcoder output is guaranteed. Our internal delivery mechanism, The Topcoder Way, ensures predictable crowdsourced delivery every time we do work together.
  6. We manage projects for you – We’ll do the heavy lifting of project management with input from you for project iteration. You can keep working how you’re already working because we’ll learn your standards and work within that framework
  7. You can keep working where you’re already working – Topcoder features an open API so your organization can bring the dev tools you’re already using OR work directly on the Topcoder Platform, seamlessly. You can do work from GitLab, GitHub, Azure DevOps, and comms through tools such as Slack, to name a few. 
  8. Consulting through Wipro – Looking beyond compliance to the new competitive environment that follows, the companies who thrive will be those with proactive strategies to capitalize on the opportunities in this change. Leverage our expertise domain, technology and disruptive business models to help make sure you’re ready.  

“Topcoder was my only labor source not affected by the pandemic” 

Paul Hlivko, CTO, Wellmark Blue Cross Blue Shield July 2020


Download a free Interoperability & Patient Access Final Rule (CMS-9115-F) Project Plan. Use this resource to guide your implementation efforts internally and stay on track to compliance. Download your Interoperability and Patient Access Rule Project Plan.

“We’re excited to partner with Topcoder for 3 things, that’s quality, speed, and results.”

– Luke Faeth, Wellmark Blue Cross Blue Shield

Annika Nagy

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