CMS-0057-F Payer-to-Payer API
The Payer-to-Payer API moves a patient's data between health plans: when a patient joins a new impacted payer (or holds concurrent coverage) and opts in, the new payer must request, and the previous payer must serve, up to five years of claims, encounter, clinical, and prior authorization data over a FHIR R4 Bulk Data exchange, by January 1, 2027.
| Trigger | Plan change or concurrent coverage, with patient opt-in |
|---|---|
| Must exchange | Claims, encounter, clinical, and prior authorization data from the previous five years (excluding remittances and cost-sharing) |
| Mechanism | FHIR R4 Bulk Data Access 1.0 (the flat-file NDJSON export flow; part of the required 45 CFR 170.215 baseline) |
| Timing | New-enrollee data requested within one week of coverage start; responses within one business day of a request |
| Deadline | January 1, 2027 |
Example
Readiness checklist
1. Build both directions: the requesting flow for members joining you, and
the serving flow for members leaving you.
2. Implement the opt-in capture at enrollment and the identity-matching step
between plans.
3. Assemble the five-year lookback payload from the same USCDI classes the
Patient Access API serves.
4. Stand up the Bulk Data export ($export, async status polling, NDJSON
output files).
5. Gate the underlying FHIR resources in CI before exchange testing with a
partner plan:
pidgeon data install fhir-us-core-6.0 # package id says 6.0; installs US Core STU 6.1
pidgeon conform \
--endpoint https://fhir.example.com \
--ig http://hl7.org/fhir/us/core/ \
--walk --cipidgeon conform validates resource instances the endpoint serves; it does not exercise the Bulk Data $export flow itself. Use it to produce conformance evidence for the resources inside the export before partner testing.
Validation context
Strict and compatibility validation notes land here with the phase-1 data export.
This answer, in your terminal
pidgeon conform --endpoint https://fhir.example.com --walk --ciWire it into your AI agent:
claude mcp add pidgeon -- npx -y @pidgeonhealth/mcpDownload Post free to browse this reference with generation attached.