- Mehmet C. Oz, MD, MBA
Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
7500 Security Boulevard
Baltimore, MD 21244 - Abe Sutton, JD
Deputy Administrator and Director
Center for Medicare & Medicaid Innovation
Centers for Medicare & Medicaid Services
200 Independence Avenue, SW
Washington, DC 20201
RE: Opposition to Implementation of the WISeR Model in Medicare Fee-for-Service
Dear Dr. Oz and Mr. Sutton:
On behalf of the Regulatory Relief Coalition (RRC), we write to express our strong concerns about the Centers for Medicare & Medicaid Services’ (CMS) implementation of the Wasteful and Inappropriate Service Reduction (WISeR) Model in the Medicare Fee-for-Service (FFS) program. The RRC is a coalition of national physician specialty organizations seeking to reduce regulatory burdens that interfere with patient care. Our recent activities focus on ensuring that utilization review policies are not a barrier to timely and necessary access to care for the patients we serve.
Implementation of the WISeR Model is completely inconsistent with the Administration’s commitment to reducing the administrative burden of federal regulatory and other administrative requirements. The overwhelming evidence is that prior authorization (PA) imposes extraordinary administrative burdens on providers and significantly interferes with the efficient delivery of healthcare services to patients, including Medicare beneficiaries enrolled in Medicare Advantage. For example, a physician survey conducted by RRC found, among other things, that:
- Eighty-two percent of respondents state that PA always (37%) or often (45%) delays access to necessary care;
- Wait times can be lengthy: For most physicians (74%), it takes between 2 to 14 days to obtain PA, and for 15%, this process can take 15 to more than 31 days;
- Thirty two percent (32%) of respondents report that patients often abandon treatment and 50% report that patients sometimes abandon treatment;
- Overwhelmingly (87%), physicians report that PA has a significant (40%) or somewhat (47%) negative impact on patient clinical outcomes;
- The burden associated with PA for physicians and their staff is high or extremely high (92%); and
- Ultimately, most services are approved, with one-third of physicians getting approved 90% or more of the time
Click here to view the full Neurosurgery Opposes CMS Prior Authorization Demonstration Project
