Part II: The Jan 2027 Prior Authorization Reckoning: FHIR API Mandates, the Two Year MIPS Attestation Ramp, ONC Certification Gates & Why the Real Money Sits Between the Payer Endpoint and the Order

CMS prior auth FHIR APIs are not a proposed rule. They are a January 1, 2027 hard deadline for MA plans, Medicaid managed care, CHIP, and federally facilitated exchange issuers.

The decision clocks already went live in 2026: 72 hours for expedited requests, 7 calendar days for standard. Specific denial reasons required. Public reporting of PA metrics sta…