Compliance with CMS Interoperability & Patient Access Final Rule


The Emids client is a not-for-profit 501c3 health maintenance organization (HMO) insurance company with a consistent record of earning accreditation by the National Committee for Quality Assurance (NCQA).

Emids partnered to help them build the right capabilities that comply with Centers for Medicare and Medicaid (CMS) regulatory requirements related to Interoperability and Patient Access final rules. These regulatory requirements are applicable to the client’s LOBs – Medicaid and Duals only.

The Challenge

Developing interoperability preparedness for not only regulatory compliance but “beyond the rules” readiness.

Emids Solution

Our team performed a discovery assessment to understand as-is state and data ingestion process, data flows, technology and integration tools. We carried out a detailed assessment around FHIR integration, “Build on Cloud” solution approach, and discovered FHIR resource gaps within the current data landscape.

Based on our analysis, we explored multiple options to comply with the CMS Interoperability mandate, developed a future state architectural blueprint, identified selective use cases related to regulatory mandates and created a detailed implementation road map, including an overall operating model.

Our team implemented a selected interoperability solution option including cloud infrastructure setup, building authentication and authorization mechanism using OKTA, implementing an FHIR server for exchange as well as storage of healthcare data exchange and exposing data using FHIR compliant APIs. This solution approach was forward-thinking to anticipate and build new member engagement and data analytics capabilities down the line.


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In 10 months we helped the client meet the Patient Access API & Provider Directory API deadline of CMS mandate.

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