Comment on CMS-2026-1255-0001

To the Centers for Medicare & Medicaid Services, Zelo Health Inc. is a CMS Health Tech Ecosystem early adopter in the Conversational AI Assistants category. We build a patient and caregiver facing application that aggregates a person's health records through FHIR APIs and helps families coordinate care, including managing complex, multi-medication regimens for older adults. We strongly support the proposal to extend prior authorization interoperability requirements to drugs and to adopt FHIR R4 as the standard for prior authorization transactions. Three points from the caregiver perspective: First, FHIR-based drug prior authorization closes a critical visibility gap. Caregivers managing a parent's medications today have no reliable way to see where a prior authorization stands. They learn about delays only when a prescription is denied at the pharmacy counter. FHIR-accessible PA status, delivered through the same patient-authorized API pipeline that already syncs medications, would let a caregiver see in one place that a medication is approved, pending, or denied, and act before a gap in therapy occurs. Second, standardized API endpoints and a centralized payer endpoint registry are essential for patient-access applications. Without a common FHIR standard and a discoverable endpoint directory, each payer connection becomes a bespoke integration, which keeps this data out of reach for the consumer-facing apps that patients and families actually use. Third, the proposed decision deadlines (24 hours urgent, 72 hours standard) are meaningful for the populations caregivers support. Older adults on multiple chronic medications are the patients most harmed by PA delays, and the most dependent on a family member to track them. We encourage CMS to finalize FHIR R4 as the prior authorization standard and to require that prior authorization status be available to patient-authorized applications, not only to providers and payers. Respectfully submitted, Simon Lorenz CEO, Zelo Health Inc.