Three weeks after the CMS-0057-F deadline, compliance hasn’t moved. Our automated pipeline re-ran on April 19 against the same 1,304 impacted payers. Same result as week two: 9% partially compliant, 1,185 publishing nothing. The silence is now measurable — payers who missed the March 31 deadline are, overwhelmingly, not rushing to fix it.
Under CMS-0057-F, these payers were required to publicly report their 2025 prior authorization metrics: approval rates, denial rates, appeal outcomes, and average decision times.
Here’s the week-three snapshot, and what non-movement tells us.
The Bottom Line
9% of assessed payers are at least partially compliant. That means 1185 out of 1304 payers we checked showed no evidence of publishing their required PA metrics.
| Grade | Count | Percentage |
|---|---|---|
| A | 7 | 0.5% |
| B | 111 | 8.5% |
| C | 1 | 0.1% |
| D | 69 | 5.3% |
| F | 1116 | 85.6% |
Metrics Reporting: The March 31 Mandate
Of 1273 payers checked for metrics publication:
- 119 published PA metrics data (score 2-3/3)
- 1103 had no discoverable PA metrics whatsoever (score 0/3)
Compliance by Payer Type
| Payer Type | Assessed | Compliant (C+) | Rate |
|---|---|---|---|
| CHIP | 51 | 4 | 8% |
| MA | 975 | 72 | 7% |
| Medicaid_FFS | 56 | 4 | 7% |
| Medicaid_MCO | 30 | 0 | 0% |
| QHP | 192 | 39 | 20% |
Most Compliant Payers
- Utah Medicaid FFS (Grade A) — N/A enrolled, metrics: 3/3 — metrics page
- Wisconsin Medicaid FFS (Grade A) — N/A enrolled, metrics: 3/3 — metrics page
- Wyoming Medicaid FFS (Grade A) — N/A enrolled, metrics: 3/3 — metrics page
- Utah Children’s Health Insurance Program (Grade A) — N/A enrolled, metrics: 3/3 — metrics page
- Wisconsin Children’s Health Insurance Program (Grade A) — N/A enrolled, metrics: 3/3 — metrics page
Largest Payers With No Evidence of Compliance
- Wellcare (S4802) — 8,889,493 enrolled
- Aetna Medicare (S5601) — 4,243,140 enrolled
- Ambetter (Centene) QHP — 4,200,000 enrolled
- Humana (S5884) — 3,796,299 enrolled
- Blue Cross Blue Shield QHP — 3,000,000 enrolled
What CMS Required
Under CMS-0057-F, payers must report eight metrics for medical items and services (excluding drugs):
- List of all items/services requiring prior authorization
- Percentage of standard PA requests approved
- Percentage of standard PA requests denied
- Percentage approved after appeal
- Percentage where timeframe was extended and then approved
- Percentage of expedited requests approved
- Percentage of expedited requests denied
- Average and median time from submission to decision
Note: CMS suspended the health equity breakdown and plan-level granularity requirements in June 2025. The aggregate metrics above remain in effect.
Methodology
We built an automated compliance checker that:
- Crawled each payer’s website checking common transparency page paths
- Searched for PA metrics keywords and machine-readable data indicators
- Probed known FHIR endpoints for Da Vinci profile support
- Scored each payer on a 0-3 scale, then assigned letter grades
Scores are based on what we could discover through public web crawling. Payers may have published data in locations we didn’t check — if you know of corrections, contact us.
What This Means
The prior authorization system processes over 50 million determinations per year in Medicare Advantage alone. Transparency is the first step toward accountability. The payers who published their data deserve credit. Those who didn’t are failing their members and the providers who serve them.
The January 1, 2027 deadline for FHIR-based PA APIs is next. We’ll be tracking that too.
This analysis is part of Artificer Health’s ongoing monitoring of CMS-0057-F compliance. Updated data is available at artificerhealth.com/compliance.