The business case for embracing electronic prior authorization, or ePA, nationwide seems overwhelming. Current prior authorization processes are a chief driver of provider and patient frustration. Needed investment in FHIR APIs is now mandated by CMS Rule 0057, and ePA pilots report dramatic efficiency gains. More specifically, providers in such pilots were automatically notified that no prior authorization was needed for 50%-85% of requests. Nonetheless, reservations about the scalability of ePA persist and, in turn, spur questions about the minimum investment needed just to comply with CMS 0057.