• Mehmet Oz, MD, MBA
    Administrator
    Centers for Medicare and Medicaid Services
    Department of Health and Human Services
    200 Independence Avenue SW
    Washington, DC 20201
  • Thomas Keane, MD, MBA
    National Coordinator for Health IT
    Office of the National Coordinator for Health IT
    Department of Health and Human Services
    330 C St SW, Floor 7
    Washington, DC 20201


Submitted electronically via www.regulations.gov

RE: Interoperability Standards and Prior Authorization for Drugs for Medicare Advantage Organizations, Medicaid Managed Care Plans, State Medicaid Agencies, Children’s Health Insurance Program (CHIP) Agencies and CHIP Managed Care Entities, and Issuers of Qualified Health Plans on the Federally-Facilitated Exchanges (CMS-0062-P)

Dear Administrator Oz and National Coordinator Keane,

The Alliance of Specialty Medicine (the “Alliance”) represents more than 100,000 specialty physicians across 15 specialty and subspecialty societies who are committed to improving access to specialty medical care by advancing sound health policy. On behalf of the undersigned members, we appreciate the opportunity to comment on the aforementioned proposed rule to improve the electronic exchange of health care data and streamline prior authorization processes through enhanced interoperability.

The Alliance greatly appreciates that this rule builds on previous finalized regulations that we generally supported, including the 2024 CMS Interoperability and Prior Authorization final rule (“2024 final rule”), which aimed to improve the electronic exchange of health care data and streamline prior authorization by requiring impacted payers to automate prior authorization processes, accelerate decision timelines, improve data exchange through the adoption of standards, and enhance transparency by requiring payers to provide specific denial reasons and publicly report prior authorization metrics.

Click here to view the full Comments on Interoperability Standards and Prior Authorization for Drugs (CMS-0062-P)