On January 15, 2021, the Centers for Medicare & Medicaid Services (“CMS”) issued the final rule for CMS Interoperability and Prior Authorization (the “Final Rule”) to improve the prior authorization process and give patients more control in accessing and understanding their health information. Under the Final Rule, certain payers, such as Medicaid and CHIP managed care plans, state Medicaid and CHIP fee-for-service (“FFS”) programs and those that issue individual market qualified health plans (“QHPs”) on the federally-facilitated exchanges (“FFEs”) must develop and implement technology known as application programming interfaces (“APIs”). APIs are commonly used in smartphone applications, and when incorporated
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