For years, delegating utilization management (UM) functions to third-party vendors was seen as a practical response to rising medical costs, regulatory complexity, and distributed networks. Vendors promised operational relief, clinical efficiency, and scalable expertise. But what once looked like a smart outsourcing strategy is now revealing cracks and, in many cases, exposing health plans to new risks.

Recent federal regulation, particularly CMS’s Interoperability and Prior Authorization Final Rule ( CMS-0057 ), has made it clear that responsibility for timeliness, transparency, and documentation of prior authorization decisions cannot be offloaded. Meanwhile, the pledge created by AHIP and the Blue Cross Blue Shield Association, adopted by most major commercial plans, has committed

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