Deadline Calendar

The verified compliance anchors across the CMS prior-authorization rulemaking wave, organized by date. Every anchor below is drawn from the curated OBLIGATION_APPLICABILITY facts and is reproducible from the COMPLIANCE_DEADLINES view — this page is a narrative rendering of the same data, not a separate source. Final and proposed dates are marked; proposed dates come from CMS-0062-P and are not binding.

Informational reference compiled from public Federal Register, eCFR, and CMS sources. Not legal advice; consult counsel for compliance decisions. Dates key off entity-specific semantics — see How the anchors read per entity before treating any anchor as a literal due date.

Milestone timeline

Anchor	What is due	Rule	Certainty	Status
Apr 8, 2024	Patient Access API — expanded data content (all USCDI classes) for impacted payers	CMS-0057-F	Final	In effect
Jan 1, 2026	PA decision timeframes — 72h expedited / 7 calendar days standard (all impacted payers except QHP issuers on the FFEs, who are exempt)	CMS-0057-F	Final	In effect
Jan 1, 2026	Denial-reason specificity, any communication channel (all impacted payers)	CMS-0057-F	Final	In effect
Jan 1, 2026	Public reporting of PA metrics begins (all impacted payers)	CMS-0057-F	Final	In effect
Mar 31, 2026	First public PA-metrics posting due on payer websites (for CY2025), recurring annually thereafter	CMS-0057-F	Final	In effect · recurs annually (next Mar 31, 2027)
Mar 31, 2026	First Patient Access API usage metrics reported to CMS (for CY2025), recurring annually	CMS-0057-F	Final	In effect · recurs annually (next Mar 31, 2027)
Jan 1, 2027	Patient Access API — add prior-authorization information	CMS-0057-F	Final	Upcoming
Jan 1, 2027	Provider Access API (extension path available for Medicaid/CHIP FFS)	CMS-0057-F	Final	Upcoming
Jan 1, 2027	Payer-to-Payer API (extension path available for Medicaid/CHIP FFS)	CMS-0057-F	Final	Upcoming
Jan 1, 2027	Prior Authorization API — CRD + DTR + PAS capability (extension path available for Medicaid/CHIP FFS)	CMS-0057-F	Final	Upcoming
CY2027	MIPS Electronic Prior Authorization measure — performance period (clinicians and eligible hospitals/CAHs)	CMS-0057-F	Final	Upcoming
Oct 1, 2027	Drug prior-authorization into the Prior Authorization API; drug PA decision timeframes; drug denial-reason specificity; NCPDP pharmacy PA standards; public drug-PA metrics	CMS-0062-P	Proposed	Proposed
Jan 1, 2028	Interoperability + PA API requirements extended to small-group QHP issuers on the FF-SHOPs	CMS-0062-P	Proposed	Proposed
Jan 1, 2028	STU-2-era FHIR implementation-guide stack proposed to expire	CMS-0062-P	Proposed	Proposed
May 26, 2028	Claims-attachments standards — X12N 275/277 and the C-CDA attachments IGs (claims attachments only; not prior-authorization scope)	CMS-0053-F	Final	Upcoming

Status computed as of July 7, 2026 from the anchor dates above; proposed dates are never marked in effect.

Two obligations from CMS-0062-P — adopting FHIR as the HIPAA standard replacing X12N 278, and the FHIR PA-attachments standard — attach to HIPAA covered entities with a compliance clock defined relative to a future final rule's effective date ("24 months from the effective date of a final rule"). Because no dated anchor exists yet, they carry compliance_date_type = RELATIVE_TO_FINALIZATION with a NULL anchor and are quarantined from the gold view — the date is tracked, never fabricated, and will resolve when CMS-0062-P is finalized.

How the anchors read per entity

The same anchor date means different things for different entity types. This is why the product never publishes a bare compliance_date — the anchor is paired with a compliance_date_type that tells you how to resolve it.

Entity type	Default date semantics	How to read a Jan 1 anchor
Medicare Advantage organizations	LITERAL	The literal calendar date
State Medicaid / CHIP fee-for-service	LITERAL	The literal calendar date
Medicaid / CHIP managed care	RATING_PERIOD_ON_OR_AFTER	The first rating period beginning on or after the anchor
QHP issuers on the FFEs (and FF-SHOPs)	PLAN_YEAR_ON_OR_AFTER	The first plan year beginning on or after the anchor
MIPS clinicians / eligible hospitals & CAHs	PERFORMANCE_PERIOD	The applicable EHR reporting / performance period

Resolving a managed-care plan's actual due date requires its rating-period start, and a QHP's requires its plan-year start — neither is in the rule text, so the product supplies the anchor and the semantics and leaves the final resolution to the entity. Query OBLIGATION_APPLICABILITY (or COMPLIANCE_GOLD) with your entity_type_id to get the anchor and its semantics for every obligation.

Extensions and exemptions

These are first-class rows, not footnotes:

• QHP issuers on the FFEs are exempt from the PA decision-timeframe obligation — an explicit EXEMPT applicability row, not a missing one.

• Medicaid and CHIP fee-for-service programs have an extension path on the Provider Access, Payer-to-Payer, and Prior Authorization APIs — EXTENSION_AVAILABLE applicability, with the basis in extension_exemption_notes.

• CMS-0053-F rows are adjacency only — every one carries is_pa_scope = FALSE. They appear in the calendar because the May 26, 2028 claims-attachments date is a real CMS deadline payers track, but they are not prior-authorization obligations, and CMS explicitly declined to finalize X12N 278 for prior-authorization attachments (the gap CMS-0062-P proposes to fill with FHIR).

Reproduce this calendar

SELECT
    deadline_type,
    entity_type_id,
    obligation_id,
    compliance_date_anchor,
    compliance_date_type,
    compliance_date_display,
    date_certainty
FROM DWV.COMPLIANCE_DEADLINES
ORDER BY compliance_date_anchor, date_certainty DESC, entity_type_id;

---

Informational reference compiled from public Federal Register, eCFR, and CMS sources. Not legal advice; consult counsel for compliance decisions.