Comment Letter

Neurosurgery Joins Alliance in Commenting on Prior Auth Rules

  • Reimbursement and Practice Management

Chiquita Brooks-LaSure
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-4201-P
P.O. Box 8016
Baltimore, MD 21244-8016

RE: Medicare Program; Contract Year 2024 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, Medicare Parts A, B, C, and D Overpayment Provisions of the Affordable Care Act and Programs of All-Inclusive Care for the Elderly; Health Information Technology Standards and Implementation Specifications

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 for Medicare Advantage Organizations (MAOs) and their impact on access to specialty medical care.

Utilization Management Requirements
The Alliance greatly appreciates CMS’ proposals to meaningfully improve utilization management (UM) in the Medicare Advantage (MA) program and urges CMS to finalize these policies. These proposed reforms come after years of provider and patient advocacy and multiple agency initiatives to reduce administrative burdens. We are extremely pleased that CMS has heard our concerns and recognizes the need to take action. These proposed reforms are particularly important for specialty physicians and their patients, who are often subject to prior authorizations and other UM tactics. They are particularly timely as the MA program continues to grow, with 60% of beneficiaries expected to be enrolled by 2032.1 Again, we laud CMS for the proposed policies in this rulemaking and urge their finalization.

Click here for the full Neurosurgery Joins Alliance in Commenting on Prior Auth Rules.