Comment Letter

AANS and CNS Join Nearly 120 Groups in Commenting on Prior Auth Proposal

  • Reimbursement and Practice Management

The Honorable Chiquita Brooks-LaSure
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Hubert H. Humphrey Building, Room 445–G
200 Independence Avenue, SW
Washington, DC 20201

Dear Administrator Brooks-LaSure:

On behalf of the undersigned organizations representing physicians across the country, we thank you for listening to our concerns, as well as those of our patients, and proposing meaningful prior authorization (PA) reforms in the Centers for Medicare & Medicaid Services’ (CMS’) Notice of Proposed Rule Making for Part C & Part D (CMS–4201–P) (“proposed rule”) that will increase access to medically necessary care.

Recent American Medical Association (AMA) survey data show that 93 percent of physicians report care delays or disruptions associated with PA. AMA data also show that 34 percent of physicians report that PA has led to a serious adverse event (e.g., hospitalization, permanent impairment, or even death) for a patient in their care and that 91 percent of physicians see PA as having a negative effect on their patients’ clinical outcomes. Moreover, the Office of Inspector General (OIG) 2022 report found that 13 percent of PA requests denied by Medicare Advantage (MA) plans met Medicare coverage rules, and 18 percent of payment request denials met Medicare and MA billing rules. We applaud CMS’ proposed policy responses to the findings of the OIG’s report and to ongoing stakeholder concerns and urge CMS to finalize these policies to help protect beneficiaries’ access to medically necessary care.

Click here to read the full AANS and CNS Join Nearly 120 Groups in Commenting on Prior Auth Proposal.