From Checking the Box to Fueling the Flywheel: Why Health Plans Must Go Beyond FHIR Facade Solutions

HHS, CMS, and ONC have long been driving forces behind regulations and initiatives that encourage patient access and shoppable experiences, but with the recent RFIs from CMS in conjunction with the ASTP/CMS and HHS for transforming the health tech ecosystem and reviving price transparency, we are at a new inflection point. From patient access and interoperability the federal government is moving with breakneck speed to enable a national healthcare directory, digital identity, price transparency, scheduling, enriched digital insurance cards and prior authorization reform, the federal government continues to raise the bar for how data must move: bi-directionally, in bulk, and in real time, not just for static information exchange but to power dynamic interconnected applications and solutions. 

CMS-0057-F is the latest in a string of interoperability mandates specifically for health plans. That, combined with the recent RFIs showcase where industry must go:, towards standards-based infrastructure that enables true data liquidity across the ecosystem. For health plans, these are not one-off requirements. They are an essential part of the regulatory tailwinds that are shaping the future with modern infrastructure and scalable digital strategies.

To keep up, health plans must look beyond temporary solutions and embrace a solid data foundation. One that converts data into FHIR-native assets, supports modular APIs, adapts over time, and opens up new revenue streams. For many organizations, the initial investment in compliance is already underway. As more rulemaking evolves, health plans must expect sustained gusts that require them to adopt platform-based technology strategies and investments that enable their information to become real-time, high-fidelity computable data, so it becomes a renewable, reusable and extensible resource.  In short, an asset to be leveraged: Not just to meet a handful of compliance mandates but a continuous pipeline of mandates and strategic investment opportunities. By adopting a modular and scalable architecture, health plans can meet today’s requirements, such as CMS-0057-F, while also being future-proofed for what’s next.

According to Gartner, “Organizations that treat regulatory mandates as strategic will outpace peers in delivering digital transformation.”

And those that invest in a platform to thrive in the emerging environment stand to gain even more, unlocking new capabilities to manage medical loss ratios (MLR), improve Star Ratings, support risk adjustment, perform real-time population health analytics and digital health programs,  drive member retention, and streamline administrative performance. In short, a single investment that powers compliance and competitiveness alike.

The Mandates Are Here—and They’re Not Slowing Down

The Centers for Medicare & Medicaid Services (CMS) have rolled out multiple rules requiring price transparency, interoperability, patient access, and streamlined prior authorizations. These include:

  • Hospital Price Transparency: Effective since January 1, 2021, requires all hospitals to publicly post a list of standard charges for all items and services they offer, in machine-readable format and through consumer-friendly tools.
  • Transparency in Coverage: Enforced since January 1, 2022, requires all health plans and insurance companies to publicly post in-network rates, out-of-network allowed amounts, billed charges, and negotiated prices for prescription drugs.
  • CMS-9115-F (Interoperability and Patient Access Final Rule): Effective since July 1, 2021, requires payers regulated by CMS to expose their provider directories through open, standardized APIs, and to support patient access to their claims and encounter data (including cost), plus any clinical data maintained by these payers, via FHIR standard APIs.
  • CMS-0057-F (Advancing Interoperability and Improving Prior Authorization): Finalized in January 2024, requires all CMS-regulated payers to enhance their patient access and provider directory APIs, report usage metrics, improve turnaround times for prior auth decisions by January 1, 2026, and by January 1, 2027, support even more interoperability through:
    • Prior Authorization APIs
    • Provider Access APIs and

Payer-to-Payer, the clock is ticking, and the message is clear. Compliance is mandatory table stakes. However, what matters is what you do next to capitalize on emerging requirements.

Solution Options: FHIR Facade or Health Data Management Foundation

When facing CMS mandates, payers have two options—invest in a FHIR facade or a FHIR infrastructure. 

Many health plans are tempted by quick-fix solutions that promise speed and simplicity. FHIR facade solutions fall into this category, offering bolt-on APIs that meet minimum regulatory requirements without addressing the foundational data challenges underneath. While these in-house solutions may satisfy today’s compliance deadlines, they fail to create the scalable, interoperable infrastructure needed for today’s demands and future requirements.

Enter b.well Connected Health. Our FHIR infrastructure is purpose-built to meet existing mandates while adapting to emerging standards still on the horizon. Much like HEDIS and Star Ratings, the specific measures may evolve, but the directive—to be transparent, measurable, and responsive—remains constant, and mandates will continue to expand. A unified infrastructure ensures you’re not rebuilding year after year. Of note, this same investment in a solid foundational model can also support the management of medical loss ratios (MLR), fuel quality improvement, and enhance member satisfaction and retention, driving value beyond compliance without requiring parallel investments.

In short, FHIR facade is a stopgap. It delays, rather than solves, whereas the health data management platform is the flywheel that supports compliance and is unified, consumer-ready data infrastructure.

Why b.well, Why Now?

Built for Compliance, and What Comes Next

b.well delivers complete support for both CMS-9115-F and the newly finalized CMS-0057-F, including Patient Access, Payer-to-Payer, Prior Authorization, and Provider Access APIs. Unlike limited point solutions, b.well future-proofs your compliance investments while meeting current mandates

FHIR-Native from Day One

Our platform fully converts and normalizes disparate data sources—claims, clinical, pharmacy, labs, SDOH, wearable, and device data—into longitudinal, FHIR-native assets. That means you don’t just get compliance-ready APIs; you gain a reusable, scalable data layer that can serve clinical decision-making, personalization, and automation.

Modular SDKs that Power Your Digital Strategy

b.well offers SDKs that integrate into your existing payer portals, member apps, and provider tools, making it easy to activate FHIR data across digital channels without reinventing your stack. Whether it’s surfacing prior auth statuses or enabling full health record access, we give you flexible components to create tailored user experiences.

Future-Proof Architecture, Ready for What’s Next

Built with interoperability and flexibility at its core, b.well supports price transparency, Advanced EOBs, clinical quality rules engines, GenAI-powered experiences, and more. Your compliance foundation becomes a launchpad for broader digital transformation, analytics, and revenue-driving programs.

Enterprise-Ready and Proven at Scale

We power nationwide interoperability and digital experience initiatives for some of the country’s largest healthcare organizations. With deep experience integrating into payer ecosystems and working with legacy vendors, b.well delivers rapid time-to-value, without disruption.

One Investment. Infinite Possibilities.

With b.well, compliance spend becomes strategic infrastructure. You don’t just meet mandates, you unlock new revenue opportunities, accelerate digital transformation, and enhance your ability to serve members, providers, and partners in a modern, consumer-first ecosystem.

In Conclusion: Invest Once, Reap for Years

Don’t pay twice—once for compliance, and again for innovation.

By choosing b.well’s health data management platform, health plans can solve for compliance and use that investment to deliver member-first experiences, strengthen partnerships with providers, and open new revenue streams.

Because when you stop treating compliance like a checkbox, it becomes your competitive edge.

¹ Gartner Market Guide for Health Data Management Platforms, 2024.

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