Comment Letter

AANS and CNS Join Alliance in Urging CMS to Adopt Prior Authorization Reforms

Chiquita Brooks-LaSure
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-0057-P
P.O. Box 8016
Baltimore, MD 21244-8016

RE: Advancing Interoperability and Improving Prior Authorization Processes for Medicare Advantage Organizations, Medicaid Managed Care Plans, State Medicaid Agencies, Children’s Health Insurance Program (CHIP) Agencies and CHIP Managed Care Entities, Issuers of Qualified Health Plans on the Federally-facilitated Exchanges

Dear Administrator Brooks-LaSure,

The Alliance of Specialty Medicine (the “Alliance”), representing more than 100,000 specialty physicians from sixteen specialty and subspecialty societies, is deeply committed to improving access to specialty medical care by advancing sound health policy. On behalf of the undersigned members, we write to provide feedback on proposed policy changes to advance interoperability and improve prior authorization (PA).

The Alliance very much appreciates CMS proposing this rule, which aims to reduce provider burden, increase transparency, and improve care coordination— all of which will result in higher quality patient care. In particular, we would like to thank Mary Greene, MD, and her team in the CMS Office of Burden Reduction & Health Informatics for meeting with the Alliance over the past few years and taking our concerns regarding utilization management practices, patient safety, and physician burden seriously. Most of the prior authorization proposals in this rule, together with related proposals included in the recently released Contract Year 2024 Policy and Technical Changes to the Medicare Advantage (MA) and Medicare Prescription Drug Benefit Programs proposed rule (CMS-4201-P), will play a critical role in reducing care delays and improving patient outcomes. We are particularly appreciative that CMS proposes to extend these policies to MA. In 2022, one in five Medicare beneficiaries lived in a county where at least 60% of all Medicare beneficiaries in that county were enrolled in MA plans, and that number is expected to grow.1 Prior authorization practices within MA plans, in particular, have resulted in inappropriate, unnecessary and even life-threatening barriers to care for our patients.

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