Payer-to-Payer Data Exchange Early Access
The CMS-0057 Payer-to-Payer Data Exchange enables patients to transfer their health records between health plans through a standardized FHIR-based API. This ensures continuity of care when a patient changes insurance providers.
Flexpa provides simple APIs to facilitate these transfers, including our Consent API which enables patients to authorize the exchange of their data between payers.
#Availability
Payer-to-Payer Data Exchange is currently available through our Early Access Program. We're working with a select cohort of forward-thinking payers to test implementation approaches ahead of the January 2027 CMS-0057 compliance deadline.
#Recent Updates
- January 2024: CMS-0057 final rule published with January 2027 implementation deadline for payers
- July 2024: CMS Connectathon - Flexpa publicly tests PDex in the real world with Firely
- March 2025: Flexpa hosted Payer to Payer Exchange Webinar
- Upcoming July 2025: Flexpa participating in CMS Connectathon for public payer-to-payer testing including end-to-end consent workflow, single member match, and multiple member match testing
#Early Access Program
Payer-to-payer exchange represents more than compliance—CMS-0057 uniquely positions payers as both responders and requesters, creating direct operational value.
#The Opportunity
- End the chart chase: Reduce member data acquisition from 21+ days to zero days
- Continuity of care: Prior authorizations follow patients between payers
- Cost reduction: Immediate data access for risk adjustment and star ratings
Today's challenge: 21-day average chart chase costs the industry an estimated $900 million annually across 20-30 million new enrollments per year.
#Implementation Gaps
Two critical challenges stand between compliance and value realization:
- Consent management: Patient opt-in processes for millions of current enrollees
- Network connectivity: Technical connections and trust frameworks across hundreds of payer APIs
#Flexpa's Partnership Approach
Leverage our proven expertise to accelerate your implementation:
- Largest payer network: 380+ direct connections covering 160+ million lives across Medicare, Medicare Advantage, ACA, and employer plans
- Proven consent workflows: Production-tested patient authorization processes
- Standards leadership: Active HL7 FHIR and Da Vinci PDex participation
#Early Access Program Details
We're working with a select cohort of payers to build and test the infrastructure needed for January 2027 compliance:
What's Included:
- Joint development of consent collection workflows for current enrollees
- Technical connectivity setup and validation across payer networks
- Standards-based implementation testing through HL7 Connectathons
- Real-world pilot testing with member enrollment scenarios pre-2027
- Platform licensing available starting 2027 with full launch
Collaboration Approach:
- Flexpa acts as your coordinating representative in public participation in industry forums (HL7, FAST, Da Vinci)
- Private pilot environments for safe testing and iteration
- Flexpa directly embeds FHIR interoperability engineers on your team for hands-on implementation support
Timeline:
- Now - Q4 2025: Joint development of consent collection workflows, technical connectivity setup, and standards-based implementation testing through HL7 Connectathons
- Q1 - Q4 2026: Real-world pilot testing, establishment of network connectivity with other payers, and scale preparation for current enrollee consent collection
- Q4 2026: Platform licensing available with full launch
- January 2027: Readiness to end the chart chase for good
Ready to end the chart chase for good? Contact partnerships@flexpa.com to join our early access cohort.
#Consent
The Consent API leverages Flexpa's existing Consent SDK to provide a streamlined patient-facing UI for obtaining opt-in consent for payer-to-payer data exchange and also opt-out consent for payer-to-provider exchange. Our SDK handles the entire consent workflow:
- Consent Collection: Presents a clear, user-friendly interface for data sharing authorization
- Consent Management: Tracks consent status, expiration, and revocation options
- FHIR Consent Generation: Upon completion, generates a compliant HRex Consent Profile resource
The generated Consent resource can be used as part of the $member-match operation input as defined in the Da Vinci PDex Implementation Guide. This approach ensures proper documentation of patient consent and compliance with regulatory requirements.
You can implement this solution either:
- As a standalone consent management system integrated with your own payer-to-payer implementation
- As part of Flexpa's complete Network and Records exchange implementation that handles the entire Da Vinci PDex workflow
GEThttps://api.flexpa.com/fhir/Consent
Search for and retrieve Consent records for a given member / patient.
Request headers
- AuthorizationstringRequired
An Authorization: Bearer header value must be presented with a Patient Access Token
Request parameters
- statusstring
Filter by consent status (e.g., "active", "inactive").
Response
Returns a Bundle of Consent resources that match the search criteria.
ACCESS_TOKEN=flexpa-link-access-token
curl https://api.flexpa.com/fhir/Consent \
-H "Authorization: Bearer $ACCESS_TOKEN"
Response
{
"resourceType": "Bundle",
"type": "searchset",
"total": 1,
"entry": [
{
"resource": {
"resourceType": "Consent",
"id": "f8aa4a8a-8675-4214-9da7-cea43de5a945",
"meta": {
"profile": [
"http://hl7.org/fhir/us/davinci-hrex/StructureDefinition/hrex-consent"
]
},
"contained": [
{
"resourceType": "Patient",
"id": "patient-1",
"meta": {
"profile": [
"http://hl7.org/fhir/us/davinci-hrex/StructureDefinition/hrex-patient-demographics"
]
},
"name": [
{
"family": "Smith",
"given": ["Jane"]
}
],
"gender": "female",
"birthDate": "1970-01-25",
"address": [
{
"line": ["123 Main St"],
"city": "Anytown",
"state": "CA",
"postalCode": "12345",
"country": "US"
}
],
"identifier": [
{
"type": {
"coding": [
{
"system": "http://terminology.hl7.org/CodeSystem/v2-0203",
"code": "MB",
"display": "Member Number"
}
]
},
"value": "12345"
}
]
}
],
"status": "active",
"scope": {
"coding": [
{
"system": "http://terminology.hl7.org/CodeSystem/consentscope",
"code": "patient-privacy",
"display": "Privacy Consent"
}
]
},
"category": [
{
"coding": [
{
"system": "http://terminology.hl7.org/CodeSystem/v3-ActCode",
"code": "IDSCL",
"display": "information disclosure"
}
]
}
],
"patient": {
"reference": "#patient-1"
},
"dateTime": "2025-01-01T15:30:00Z",
"organization": [
{
"display": "Source Health Plan"
}
],
"provision": {
"type": "permit",
"period": {
"start": "2025-01-01T15:30:00Z",
"end": "2025-12-01T15:30:00Z"
},
"action": [
{
"coding": [
{
"system": "http://terminology.hl7.org/CodeSystem/consentaction",
"code": "disclose",
"display": "Disclose"
}
]
}
]
}
}
}
]
}
#Records
Once consent is established, the Records API can be used to initiate and track the transfer of patient data between payers. The API handles the complexities of data exchange, ensuring that all required information is properly transferred according to the CMS-0057 requirements.
#Key Records Features
- $member-match Implementation: Full support for the Da Vinci PDex
$member-match operation, which enables secure patient matching between payers
- Standards-Based Exchange: Implementation follows the Da Vinci PDex Implementation Guide for interoperable data transfer
- Comprehensive Resource Support: Exchange includes all required resource types defined in the PDex IG:
- Clinical data (Conditions, Procedures, Medications, etc.)
- Coverage information
- Claims data (ExplanationOfBenefit)
- Data Transformation: Automatic normalization of data from various source formats to ensure consistency
- Audit Trail: Complete logging of all data exchanges for compliance and security purposes
- Privacy Controls: Fine-grained data filtering based on patient consent preferences
Coming Soon: The Records API will be available as part of Flexpa's full Payer-to-Payer implementation. Contact partnerships@flexpa.com to learn more about our roadmap and implementation timeline.
#Network
Flexpa has built the industry's largest payer FHIR network, covering hundreds of payers across the United States. Our network is designed to support the payer-to-payer data exchange requirements of CMS-0057, providing a seamless connection between health plans.
#Key Network Features
- Comprehensive Coverage: Direct connections to over 380 managed care organizations, covering the vast majority of insured Americans
- Production-Ready Endpoints: All network connections are fully tested and validated to ensure reliable data exchange
- Simplified Implementation: Eliminate the need to build and maintain individual connections to each payer
- Standards Compliance: All network connections follow the FHIR R4 standard and relevant implementation guides
- Network Intelligence: We continuously monitor and update our network as payers implement the CMS-0057 requirements
Coming Soon: The Network will be available as part of Flexpa's full Payer-to-Payer implementation. Contact partnerships@flexpa.com to learn more about our roadmap and implementation timeline.
#Resources and Further Reading
#Webinars
#Blog Posts
#Technical Documentation