CMS-0057-F Scorecard — April 26, 2026: Four Weeks Post-Deadline, Compliance Still Frozen at 9% — But the First Da Vinci PAS Endpoint Lights Up

Four weeks after the CMS-0057-F deadline, the metrics compliance number hasn’t budged. Our pipeline re-ran on April 26 against the same 1,304 impacted payers. Same 9% partially compliant. Same 1,185 publishing nothing. Same seven A’s, same 1,116 F’s. Week three to week four, no movement.

But this week’s FHIR endpoint sweep produced one genuine signal worth flagging: PACE North (H4256), a small Michigan PACE plan with 285 enrolled members, is now exposing a full Da Vinci PAS FHIR endpoint — the first 3/3 score in our entire survey.

Here’s the week-four snapshot, what didn’t move, and why a 285-member plan is suddenly the most interesting payer in the dataset.

The Bottom Line

9% of assessed payers are at least partially compliant. That means 1,185 out of 1,304 payers we checked showed no evidence of publishing their required PA metrics.

Zero movement on grades. The grade distribution this week is identical to week three. The same identical to week two. The metrics-publication needle has not moved since April 12.

The One Thing That Moved: PACE North’s Da Vinci PAS Endpoint

The CMS-0057-F final rule has two distinct deadlines. The March 31, 2026 deadline (which everyone is failing) requires payers to publish their 2025 prior authorization metrics. The January 1, 2027 deadline requires payers to expose FHIR-based APIs that conform to the Da Vinci HRex profiles — Prior Authorization Support (PAS), Documentation Templates and Rules (DTR), Patient Access (PDex) and US Core.

A working Da Vinci PAS endpoint is what actually closes the prior-authorization-as-fax-machine loop. Metrics publication is transparency. PAS is automation. The 2027 deadline is the bigger lift.

This week, our FHIR endpoint scanner found one. PACE North — a small PACE (Program of All-Inclusive Care for the Elderly) plan in Michigan, contract H4256, 285 enrolled members — is publishing an endpoint at fhir-api.fhirprod.aws.greenwayhealth.com that returns a CapabilityStatement advertising PAS, DTR, PDex and US Core profiles. Response time: 1.16 seconds. FHIR version: 4.0.1. Score: 3/3.

This is the first endpoint in our survey of 1,308 payers that scores a full 3/3. Previous weeks: zero.

A few things to say about it.

First, this is real. We probed the CapabilityStatement and confirmed the profiles are advertised. We have not (and could not) verify that the endpoint actually round-trips a full PAS transaction with claims data — that requires authenticated test traffic. But the endpoint is live, returns FHIR R4, and claims to support the Da Vinci profile set that CMS-0057-F requires for the 2027 deadline.

Second, this is small. PACE North has 285 enrolled members. The largest non-compliant payer, Wellcare, has 8.9 million. PACE North’s compliance is not an industry signal in the enrollment-weighted sense. It is, however, a proof of existence. A real US payer is exposing a real Da Vinci PAS endpoint, eight months before the deadline. The technology works. The standards work. Other payers cannot any longer claim that the spec is impossible.

Third, the technology stack matters. The endpoint runs on Greenway Health infrastructure — a small/mid-tier EHR vendor. This isn’t Epic or Oracle Health. The market dynamic worth watching: if a regional EHR vendor can deliver a working Da Vinci PAS endpoint for a 285-member PACE plan, the bigger vendors have no technical excuse for the much larger plans they serve.

Fourth, the rest of the FHIR landscape is unchanged. We tested 61 FHIR endpoints this week (one more than last week, courtesy of the Lantern dataset refresh). Of those:

• 1 endpoint scores 3/3 (Da Vinci PAS) — PACE North
• 4 endpoints score 2/3 (some Da Vinci profiles, no PAS) — same set as last week
• 31 endpoints score 1/3 (basic FHIR R4, no Da Vinci profiles)
• 25 endpoints non-functional or unreachable

The four 2/3 endpoints are what they were. None of them surfaced PAS this week. PACE North is a singleton.

Metrics Reporting: The March 31 Mandate, Now Four Weeks Stale

Of 1,273 payers checked for metrics publication:

• 119 published PA metrics data (score 2-3/3) — same as week three
• 1,103 had no discoverable PA metrics whatsoever (score 0/3) — same as week three

Same numbers. Three weeks of zero net movement on the metrics deadline. At this point the question is not “when will the next batch of payers publish” but “will any of them ever publish without enforcement action.”

Compliance by Payer Type

Medicaid MCOs remain at 0% compliant. QHP issuers remain the highest-compliance segment at 20%, which is a low bar to clear and most QHP issuers are still not clearing it.

Most Compliant Payers (No Change Week-Over-Week)

1. Utah Medicaid FFS (Grade A) — N/A enrolled, metrics: 3/3 — metrics page
2. Wisconsin Medicaid FFS (Grade A) — N/A enrolled, metrics: 3/3 — metrics page
3. Wyoming Medicaid FFS (Grade A) — N/A enrolled, metrics: 3/3 — metrics page
4. Utah Children’s Health Insurance Program (Grade A) — N/A enrolled, metrics: 3/3 — metrics page
5. Wisconsin Children’s Health Insurance Program (Grade A) — N/A enrolled, metrics: 3/3 — metrics page
6. Wyoming Children’s Health Insurance Program (Grade A) — N/A enrolled, metrics: 3/3
7. Sendero Health Plans, Local Nonprofit (TX) (Grade A) — metrics: 3/3

Same seven payers as last week. Three small-state Medicaid programs (Utah, Wisconsin, Wyoming) plus their CHIP counterparts plus one Texas QHP issuer (Sendero). None of the major MA plans are anywhere near this list.

Largest Payers With No Evidence of Compliance

1. Wellcare (S4802) — 8,933,706 enrolled (+44,213 from last week per CMS data refresh)
2. Aetna Medicare (S5601) — 4,213,309 enrolled (-29,831)
3. Ambetter (Centene) QHP — 4,200,000 enrolled
4. Humana (S5884) — 3,821,858 enrolled (+25,559)
5. Blue Cross Blue Shield QHP — 3,000,000 enrolled

The enrollment shifts come from this week’s CMS Monthly Enrollment refresh. None of the top five non-compliant payers published anything this week.

Ground Truth Refresh: 1,308 Payers, Two Name Changes

We refreshed the payer registry this week from CMS source data. Result: same 1,308 payers in the universe. Nothing missing, nothing newly added.

Two contract-name changes worth noting:

• HealthSpring (S5715) is now reported by CMS as Blue Cross and Blue Shield of IL, NM, OK, TX (S5715) — a Cigna-to-HCSC contract reassignment
• CalOptima PACE (H7501) has been renamed to CalOptima Health PACE (H7501)

Both contracts remain non-compliant. Names updated; substance unchanged.

What CMS Required

Under CMS-0057-F, payers must report eight metrics for medical items and services (excluding drugs):

1. List of all items/services requiring prior authorization
2. Percentage of standard PA requests approved
3. Percentage of standard PA requests denied
4. Percentage approved after appeal
5. Percentage where timeframe was extended and then approved
6. Percentage of expedited requests approved
7. Percentage of expedited requests denied
8. Average and median time from submission to decision

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

For four weeks now, the metrics-publication compliance rate has held at 9%. The payer industry, at scale, is treating the March 31 deadline as optional. CMS has not announced enforcement actions. State insurance regulators have not stepped in. Provider trade associations have not filed complaints.

What did change this week, quietly, is that a 285-member PACE plan in Michigan stood up the first working Da Vinci PAS endpoint we have found. The 2027 deadline — for FHIR-based PA APIs — is still eight months away. PACE North is the first payer to demonstrate that the technology actually works in production. Watch this space: when other payers start standing up endpoints in the same architecture, the 2027 deadline will look very different than the March 31 deadline did.

The reforms are known. The standards are written. The technology works. What’s missing, four weeks into the post-deadline silence, is the political and regulatory will to use any of it.

This analysis is part of Artificer Health’s ongoing monitoring of CMS-0057-F compliance. Updated data is available at artificerhealth.com/compliance.