Recommendation

MedBridge should immediately contract with a specialist prior authorization SaaS vendor to meet the digital interoperability requirement, while running a parallel internal process redesign to close the urgent turnaround time gap, prioritizing these two workstreams above all others given that non-compliance puts $420M in CMS revenue and over $1B in annual penalty exposure at risk.

Evidence

• The financial case for compliance is unambiguous: penalty exposure of approximately $1.3B annually and $420M in CMS contract revenue at risk dwarf the $38M compliance investment, making non-compliance financially indefensible
• The digital infrastructure gap is the critical path item: at 22% digital submission rates against a full interoperability requirement, a SaaS vendor is the only realistic path to compliance within 18 months given MedBridge's limited in-house technology capability
• The turnaround time gap on urgent requests is solvable through process changes alone and does not require technology investment, freeing budget and management attention for the digital build

Risks and Mitigations

• SaaS vendor dependency creates long-term cost and control risks: mitigate by negotiating a contract that includes data portability provisions and exit rights, and evaluate a phased transition to owned technology over 3 to 5 years once the compliance deadline has passed
• Process redesign for urgent authorizations may require additional clinical review staff that are difficult to hire quickly in a tight labor market: mitigate by exploring extended hours coverage through existing staff on overtime before committing to permanent headcount additions

Next Steps

Issue an RFP to at least three prior authorization SaaS vendors within 30 days and target a signed contract within 60 days to preserve implementation runway. Launch the urgent authorization process redesign as a separate workstream immediately, with a 90-day target for full implementation. Establish a compliance program office with a dedicated executive sponsor accountable to the board for the 18-month delivery timeline.