Juliet Hodgkins
Acting Inspector General
Office of Inspector General
US Department of Health and Human Services
330 Independence Avenue, SW
Washington, DC 20201
(sent electronically)
RE: Request for HHS OIG Study on the Impacts of Step Therapy Requirements
Dear Inspector General Hodgkins,
The undersigned organizations, representing millions of Medicare beneficiaries with lifethreatening, complex, chronic conditions and the physicians who care for them, are reaching out to the Health and Human Services Office of the Inspector General (HHS OIG) to express our appreciation for the agency’s continuous focus on Medicare Advantage (MA) plans’ use of prior authorization. We also would like to share our concerns, similar to those which inspired the OIG’s reports on prior authorization, regarding MA plans continuing and expanding use of step therapy requirements for Part B drugs. For the reasons outlined below, we encourage HHS OIG to conduct a study and report on the impacts on Medicare beneficiary access to medically necessary care created by MA plans’ use of step therapy for Part B drugs.
The undersigned organizations thank HHS OIG for its thoroughly researched reports on MA plan prior authorization practices. The agency’s publications proved to be pivotal to our efforts, along with other interested stakeholders, to generate public awareness of the significant challenges prior authorization requirements impose on physicians and MA enrollees’ ability to access medically necessary care in a timely manner. The reports were an essential tool in securing landmark regulations which reformed MA plans’ use of prior authorization for utilization management: the CY 2024 Policy & Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs; the Advancing Interoperability and Improving Prior Authorization Processes. Similarly, the undersigned organizations seek to advance greater patient protections and strengthen the physician-patient relationship by ensuring step therapy requirements do not interfere with access to medically necessary physician administered therapeutics.
Click here to view the full Neurosurgery Supports HHS OIG Study on MA Step Therapy’s Impact on Part B Drugs for Medicare Enrollees
