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Compliance overview

Be compliant — and
prove it.

OMNARA tracks a live posture against the regulations that govern healthcare operations, and produces the tamper-evident evidence to demonstrate it. This overview is honest about what is built, what is deployment-time, and what requires a credentialed environment.

Readiness & evidence tracking — not a certification. Statuses below are computed from live system evidence and stated plainly. This document is an operational overview for evaluation, not a legal attestation or a substitute for a formal audit.

01

The frameworks we track

45 CFR Part 164 C

HIPAA Security Rule

Administrative, physical, and technical safeguards for electronic PHI — access control, audit controls, integrity, transmission security, and activity review.

45 CFR Part 164 E

HIPAA Privacy Rule

Uses and disclosures of PHI, the minimum-necessary standard, and an individual's right to an accounting of disclosures.

CMS-0057-F · 89 FR 8758

Interoperability & Prior Auth

The CMS Interoperability and Prior Authorization Final Rule — FHIR APIs, prior-auth decision timeframes, specific denial reasons, and metrics.

02

CMS-0057-F — ready for January 1, 2027

The rule obligates impacted payers (Medicare Advantage, Medicaid, CHIP, and QHP issuers) to stand up four FHIR APIs by January 1, 2027, and already requires — since 2026 — prior-authorization decision timeframes, specific denial reasons, and annual metrics. OMNARA is the provider-side platform: it is built to interoperate with those APIs and to meet the provider-side operational duties today.

Provider-side — implemented
  • Prior-authorization decision-timeframe tracking (72h expedited / 7-day standard)
  • Specific denial reasons captured on every denial
  • Prior-auth metrics computed and exportable as evidence
  • Electronic prior auth modeled on Da Vinci PAS / DTR, submitted through the action guard
Payer APIs — ready to consume
  • Prior Authorization API (FHIR)
  • Provider Access API
  • Payer-to-Payer API
  • Enhanced Patient Access API (with prior-auth data)

These are payer obligations. OMNARA's context and interoperability layer is structured to consume them once a credentialed payer endpoint is connected.

Sourced from the CMS-0057-F fact sheet (cms.gov) and 89 FR 8758. Confirm the final rule text before relying on specifics for your own compliance planning.

03

Control posture

Each control is graded from live system evidence. Met = the mechanism exists and is active. Partial = the platform does its part; an operator completes it at deploy. Connector = modeled and governed, live once credentialed.

ControlCitationWhat addresses itStatus
Audit controls§164.312(b)Immutable, append-only audit trail of every action and PHI accessMet
Information-system activity review§164.308(a)(1)(ii)(D)Queryable, exportable audit log; audit-coverage SLIMet
Access control (unique ID, RBAC)§164.312(a)(1)Per-user accounts, deterministic RBAC, tenant isolation (RLS)Met
Integrity§164.312(c)(1)Append-only trail, provenance, tamper-evident export hashingMet
Accounting of disclosures§164.528Every PHI access logged; filterable accounting exportMet
Minimum necessary§164.502(b)RBAC scoping; PHI kept out of logs, URLs, and promptsMet
Encryption & decryption§164.312(a)(2)(iv)Secrets encrypted at rest; PHI-at-rest/KMS is deployment-timePartial
Transmission security§164.312(e)(1)Security headers, CORS, guarded egress; TLS at deployPartial
Prior-auth decision timeframesCMS-0057-FLive 72h / 7-day adherence trackingMet
Specific denial reasonsCMS-0057-FReason captured + reported on every denialMet
Electronic prior auth (FHIR PAS)CMS-0057-FModeled on Da Vinci; guarded, simulated until credentialedConnector
04

Prior-authorization SLA

OMNARA records when each request was submitted and decided, and its priority, then reports live adherence against the regulatory limits — with at-risk and breached counts, per-priority rollups, and the share of denials carrying a specific reason. These are the exact CMS-0057-F metrics, exportable as evidence.

72h
Expedited decision limit — tracked live
7 days
Standard decision limit — tracked live
100%
Denials required to carry a specific reason
Exportable
Metrics produced as audit-ready evidence
05

Data handling & safety

Tenant isolation

Row-level security in the database scopes every query to one organization — data never crosses tenants, enforced below the application, not just in it.

PHI hygiene

PHI is kept out of application logs, URLs, and model prompts. Audit detail carries ids, counts, and flags — never raw PHI values.

Governed automation

Every external effect runs through a deterministic action guard. High-risk steps require human approval; the AI proposes and is never the authority.

No autonomous money movement

Payroll, purchase orders, and vendor payments require human approval and post balanced double-entry journals. The ledger is the system of record.

06

Proving it — tamper-evident exports

Any dataset, the immutable audit trail, or a full compliance bundle exports in standard formats. Every export is SHA-256 hashed and that hash is written into the immutable audit trail — so a downloaded file can be re-hashed later and matched against the log to prove it was not altered. Exporting PHI is itself recorded as a PHI-access event (HIPAA accounting of disclosures).

  • Tenant-scoped exports — an export can never cross organizations
  • Streamed with bounded memory, so a multi-million-row export is practical
  • Optional detached HMAC signature when a signing key is configured
07

Open items — stated plainly

These require a credentialed environment or a formal audit. They are deliberately not represented as complete.

  • Live connectors — payer FHIR (Da Vinci PAS/CRD/DTR), clearinghouse/X12, bank/ACH, distributor EDI, and identity (SSO/SCIM) — are complete, governed abstractions running in simulation until contracted.
  • Production TLS, KMS / PHI-at-rest encryption, a managed event broker, and object-storage export offload are deployment-time controls.
  • A formal WCAG 2.1 AA accessibility audit and a third-party HIPAA security assessment are prerequisites for any external compliance or certification claim.
  • Sustained multi-million-row throughput is validated on production-sized infrastructure as part of a deployment.

Bring your auditor. We'll show the trail.