b.well Connected Health has submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed rule CMS-0062-P, which establishes the accountability and operational requirements for prescription drug prior authorization and interoperability standards for Medicare, Medicaid, and health insurance issuers.
As the operator of the largest connected consumer health data network in the market, b.well supports the rule’s core objectives—patient access to real-time information about drug costs, required FHIR-based prior authorization for all HIPAA covered entities, and consistency and transparency in data exchange processes across payers. b.well offers five key recommendations to maximize patient-visible benefit by the October 1, 2027 compliance date.
Key Recommendations
Extend Real-Time Prescription Benefit Checks to Patients
The rule requires providers to see real-time prescription benefit information at point of prescribing. b.well recommends extending this same visibility to patients through the Patient Access API, with the same October 1, 2027 timeline. Patients should see out-of-pocket costs, formulary tier, prior authorization flags, and critically, cash prices alongside insurance costs, so they can make informed decisions before reaching the pharmacy counter.
Finalize the National Directory as Primary Endpoint Discovery Pathway
Today, payers publish API endpoints differently, often behind developer portals and bilateral agreements. When patients change plans, their chosen app may no longer connect. b.well recommends the Final Rule designate the FAST National Directory of Healthcare Providers and Services Implementation Guide as the primary endpoint-discovery pathway, freely available and FHIR-native, enabling patient apps to seamlessly follow them across coverage changes.
Extend HIPAA Prior Authorization Requirements to All Covered Entities
Most of this proposed rule works by telling insurance companies in Medicare and Medicaid what they have to do. But one part of it, Section II.H, works differently: it’s written into HIPAA itself, which means it would apply to every doctor, hospital, and insurer covered by HIPAA, not just the ones in government health programs. Since this section already has that broader reach, b.well recommends CMS use it to full effect: require the newer, more secure login standard (SMART App Launch v2.2 with PKCE), hold everyone to the same October 1, 2027 deadline, and set a clear timeline for making prior authorization data visible to patients through the Patient Access API.
Publish Reference Prior Authorization Questionnaires for High-Volume Drug Categories
Rather than requiring payers and EHR vendors to negotiate documentation requirements bilaterally, b.well recommends CMS commit to publishing reference Da Vinci DTR Questionnaires for the top 20 medical-benefit drug PA categories by volume within six months of finalization, accelerating implementation and ensuring transparency extends to the drugs driving the largest authorization delays.
Signal Direction Toward Real-World API Usability
Conformance testing validates specification compliance under controlled conditions, but doesn’t ensure APIs work reliably in production. b.well recommends the Final Rule acknowledge real-world API usability as the goal, commit CMS and ONC to developing robust test methods with the FHIR community over two years, and implement open third-party API access on consistent terms immediately.
The Patient Impact Case
Prior authorization delays are associated with preventable hospitalizations, disease exacerbation, and lower cancer survival. Eighty-two percent of physicians say PA can lead to treatment abandonment. About one-third of patients with PA approval never pick up their prescription because they don’t learn the cost until the pharmacy counter.
b.well’s recommendations aim to convert the rule’s structural strength into outcomes patients can use: cost transparency at the moment of prescribing, authorization decisions that travel when coverage changes, and treatment history that doesn’t reset across plans.
b.well submitted its comments on June 11, 2026. Read the submission here.
