Comment on CMS-2026-1255-0001
Drummond Group, LLCSupportBusiness
Summary: Drummond Group, LLC, a health IT compliance and certification organization, supports the proposed rule but argues that conformance testing alone is insufficient to ensure operational readiness. They advocate for mandatory multi-party interoperability testing, clearer timelines for test kit development, and the establishment of minimum security standards for FHIR implementations.
Drummond Group, LLC, a health IT compliance organization and ONC-Authorized Testing Laboratory and Certification Body, respectfully submits this formal comment on CMS-0062-P addressing substantive provisions (Sections II.A-II.J) and RFI responses (Sections III.B-III.C). The comment emphasizes three critical issues: the certification gap between standards conformance and operational readiness for prior authorization workflows, security infrastructure requirements for FHIR APIs, and the need for mandatory third-party interoperability testing before the October 1, 2027, compliance date.
Drummond appreciates the opportunity to contribute to this important rulemaking and stands ready to support CMS's implementation efforts.