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AANS and CNS Comment on Prior Authorization Reform Proposals

On Dec. 6, 2022, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule requiring Medicare Advantage plans and other public health insurers to implement automated prior authorization systems. Subsequently, on Dec. 14, 2022, CMS issued another proposed rule to improve prior authorization in the Medicare Advantage program. Taken together, the proposed rules would:

  • Require insurers to adopt electronic prior authorization;
  • Reduce care delays and improve patient outcomes by ensuring that health plans respond to prior authorization requests within specific timeframes (72 hours for urgent requests and seven days for standard requests);
  • Mandate that prior authorization approvals remain valid for a patient’s entire course of treatment;
  • Require coverage determinations to be reviewed by professionals with relevant expertise;
  • Support efforts (e.g., gold cards) to waive or modify prior authorization requirements based on provider performance; and
  • Compel health plans to publicly report the use of prior authorization, including information on delays and denials.

The AANS and the CNS responded to the proposal by joining several coalition letters.

  • Click here and here for the Regulatory Relief Coalition (RRC) letters;
  • Click here to and here read the Alliance of Specialty Medicine letter; and
  • Click here for the AMA-led letter from nearly 120 organizations.

AANS/CNS Washington Committee chair Russell R. Lonser, MD, FAANS, stated in an RRC press release, “It’s long past the time for CMS to hold health plans accountable for unconscionable delays and denials of care. Clearly, CMS listened to patients and providers when developing this rule, which will help eliminate care delays, patient harms and practice hassles that contribute to physician burnout, and is a huge step in the right direction.”