By Mark Scrimshire, Chief Interoperability Officer, Onyx
WEDI’s newest CMS-0057 survey (Nov 2025) provides an important snapshot of where payers and providers stand as the industry prepares for the January 2026 and January 2027 milestones. The results show that progress is underway, but they also reveal places where uncertainty about scope and sequencing is slowing planning.
Across the conversations we have with plans, the story is consistent. Organizations understand CMS-0057. They recognize its intent. But many lack a clear, grounded view of their operational readiness. The survey results reflect that reality.
Many Organizations Have Not Started, Highlighting the Complexity of the Work Ahead
According to WEDI:
- One-third of payers (33 percent) have not yet started CMS-0057 work, down from 43 percent earlier this year.
- Another third (33 percent) report they are about one-quarter complete, similar to the first 2025 survey.
- Nearly half of providers (47 percent) say they have not yet started, a slight improvement from 52 percent earlier in the year.
This aligns closely with what we see in the field. CMS-0057 is not a single-team effort. It spans Patient Access, Provider Access, Payer-to-Payer exchange, and the full Coverage Requirements Discovery (CRD) –Documents Templates and Rules (DTR) – Prior Authorization Support (PAS) workflow. Each domain has different owners, different systems, and different operational implications. When the starting point is unclear, teams hesitate, not because they lack urgency, but because they want to avoid missteps that create rework later.
The Barriers Are Primarily Operational, Not Technical
WEDI identifies digitizing prior authorization policies, managing timelines, and coordinating delegated entities as top payer challenges. Providers cite workflow redesign, expertise, and resources.
These challenges reflect something important. The difficulty is not the APIs themselves. FHIR implementation is well understood at this point. The real lift is operational: turning policy language into structured formats, redesigning UM processes, coordinating across clinical, network, and IT, and ensuring delegated entities can participate in the exchange. Many plans are working through these operational shifts now, and that is where the pressure shows up.
Metric Reporting Remains the Most Underestimated Requirement
January 2026 metric reporting is approaching quickly. While only 18 percent of payers say they are fully ready, the latest survey shows improvement and a sharp drop in “not yet started” responses compared with earlier this year.
Metric reporting requires consistent timestamps, aligned definitions, reliable workflow instrumentation, and a clear system-of-record strategy. These elements take time to build. Organizations typically need four to six months to instrument workflows properly, which means the practical implementation window is much shorter than the calendar suggests. These capabilities cannot be added at the end; they need to be designed early so reporting reflects actual processes, not a best-guess reconstruction.
Variation in Drug PA Plans Highlights Ongoing Interpretation Gaps
The share of payers planning to include drugs in their PA work declined from 25 percent earlier this year to 13 percent in October, while those choosing not to include drugs increased to 45 percent. This signals broader uncertainty around the flexibility CMS allows and how organizations should sequence their work. Clear interpretation of the rule and an understanding of downstream implications are essential for building sustainable workflows.
Most Plans Prefer a Phased Approach, and That Is a Wise Strategy
A majority of respondents support implementing CRD, DTR, and PAS in phases. Based on experience implementing national-scale APIs, this is a practical path. Sequencing reduces risk, supports provider adoption, and allows teams to validate assumptions before scaling. When you consider the functions provided by the CRD, DTR and PAS Implementation Guides you can see that significant benefit can come from an initial implementation of Coverage Requirements Discovery (CRD) that answers the questions: Do I need a Prior Authorization, or not?
The Common Thread: Plans Need a Clear and Objective Baseline
Across all of WEDI’s findings, one theme stands out: the greatest obstacle is not a lack of progress, but a lack of clarity about where teams stand. When readiness is uncertain, prioritization becomes difficult. When dependencies are unclear, planning slows down. And when the operational model is not well understood, sequencing becomes guesswork.
A grounded baseline gives teams the confidence to move forward. It helps avoid rework, clarify focus, and align the organization on what needs to happen next.
How our CMS-0057 Readiness Check Helps Teams Move Forward
To support plans in establishing this baseline, Onyx offers our CMS-0057 Readiness Check, the only assessment built by the team that has deployed multiple production FHIR APIs at national scale. Our one-week, expert-led review gives organizations a clear, data-driven understanding of their readiness for CMS-0057. The Readiness Check provides:
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- A quantified readiness score across all CMS-0057 domains
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- A clear view of strengths and critical gaps
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- A prioritized action plan aligned to 2026 and 2027 timelines
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- Practical recommendations that teams can act on immediately
Curious where your organization stands on metric reporting readiness? Our complimentary CMS-0057 Readiness Check provides a quantified view across all compliance domains, including the often-overlooked metric reporting infrastructure.