March 13, 2023
The Honorable Chiquita Brooks-LaSure
Administrator Centers for Medicare & Medicaid Services
7500 Security Blvd
Baltimore, MD 21244
Re: CMS 0057-P, Medicare and Medicaid Programs; Patient Protection and Affordable Care Act; Advancing Interoperability and Improving Prior Authorization Processes for Medicare Advantage Organizations, Medicaid Managed Care Plans, State Medicaid Agencies, Children’s Health Insurance Program (CHIP) Agencies and CHIP Managed Care Entities, Issuers of Qualified Health Plans on the Federally-facilitated Exchanges, Merit-based Incentive Payment System (MIPS) Eligible Clinicians, and Eligible Hospitals and Critical Access Hospitals in the Medicare Promoting Interoperability Program
Dear Administrator Brooks-LaSure:
On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations and our clinician partners — including more than 270,000 affiliated physicians, two million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to comment on the Advancing Interoperability and Improving Prior Authorization Processes proposed rule.
The AHA commends the Centers for Medicare & Medicaid Services (CMS) for taking action to remove inappropriate barriers to patient care by streamlining the prior authorization processes for the impacted health plans and providers. While prior authorization can be a tool to help ensure patients receive coverage for their care, the practice too often is used in a manner that leads to dangerous delays in treatment, clinician burnout and waste in the health care system. The proposed rule is a welcome step toward helping patients get timely access to care and clinicians focus their limited time on patient care rather than paperwork. However, to truly realize these benefits, we urge CMS to ensure a baseline level of enforcement and oversight. In addition, while hospitals and health systems appreciate CMS’ effort to improve the electronic exchange of care data to reduce provider burden and streamline prior authorization processes, we urge CMS to ensure that any electronic standards are adequately tested and vetted prior to mandated adoption.
Our detailed comments follow.