Comment Letter

Neurosurgery Joins Alliance in Commenting on CMS e-Prior Authorization Standards

  • Reimbursement and Practice Management

Micky Tripathi, PhD, MPP
National Coordinator for Health IT
Office of the National Coordinator for Health IT
Department of Health and Human Services
Mary E. Switzer Building
330 C Street SW
Washington, DC 20201
Submitted electronically via

RE: Request for Information: Electronic Prior Authorization Standards, Implementation Specifications, and Certification Criteria

Dear Dr. Tripathi:

The Alliance of Specialty Medicine (the “Alliance”) represents more than 100,000 specialty physicians and is deeply committed to improving access to specialty medical care through the advancement of sound health policy. Today, we write to share feedback in response to the aforementioned request for information (RFI) from the perspective of practicing specialty medicine providers.

Utilization Management Challenges

Utilization management protocols, including prior authorization and step therapy, create more angst and frustration for specialty physicians and their patients than any other administrative task associated with the practice of medicine. These payor-driven cost-control tactics are a primary cause of significant delays in patient access to medically necessary items and services (e.g., diagnostic tests, procedures and medication therapies), diverting clinical staff away from patient care activities and creating multiple inefficiencies that result in increased costs. These sentiments are reflected in our survey of more than 1,000 specialty physicians, where specialists reported the following:

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