What January 2027 Means for Payer-to-Payer Exchange

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December 9, 2025

Part 2 of ‘Unlocking the Payer-to-Payer Shift: Compliance, Collaboration, and Competitive Edge,’ A 6-Part Blog Series

By Jim Adamson, Senior Consultant at Point-of-Care Partners and Interoperability Matters Payer-to-Payer Workgroup Lead

The clock is ticking. In less than 13 months, CMS-0057-F requires payers to seamlessly exchange member data when patients switch health plans. Unlike previous regulations, this isn’t just about APIs—it’s about operational transformation across consent management, payer identification, and real-time data sharing.

The compliance challenge is real: Payers must implement FHIR® Release 4.0.1, manage member opt-in consent within one week of enrollment, identify previous payers, and respond to data requests within one business day. Miss any piece, and member care continuity suffers.

As lead of The Sequoia Project‘s Payer-to-Payer FHIR® API Implementation Workgroup, I’ve seen firsthand how complex this regulation is. That’s why we created the Payer-to-Payer Compliance Readiness Checklist—a practical Excel workbook that breaks down compliance into eight actionable categories, from Member Consent to Security-Privacy.

The market response? 360+ downloads and counting. Payers recognize they need a structured approach to navigate this complexity.

Your next step: Download the checklist and assess your readiness gaps. The organizations starting their structured planning now will be the ones ready for January 2027.

What’s your biggest P2P compliance concern? Share below.

About The Sequoia Project

The Sequoia Project is a non-profit, 501c3, public-private collaborative chartered to advance implementation of secure, interoperable nationwide health information exchange. The Sequoia Project focuses on solving real-world interoperability challenges and brings together public and private stakeholders in forums, such as the Interoperability Matters cooperative, to overcome barriers. The Sequoia Project is the Recognized Coordinating Entity (RCE) for the Office of the National Coordinator for Health IT’s Trusted Exchange Framework and Common Agreement (TEFCA). In this role, The Sequoia Project developed and will implement and maintain TEFCA’s Common Agreement component and operationalize the Qualified Health Information Network (QHIN) designation and monitoring process.