March 21, 2023
Mary Greene, M.D.
Director of the Office of Burden Reduction & Health Informatics
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
200 Independence Avenue, S.W.
Washington, DC 20201
Re: Administrative Simplification: Adoption of Standards for Health Care Attachments Transactions and Electronic Signatures, and Modification to Referral Certification and Authorization Transaction Standard
Dear Dr. Greene:
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 proposed Standards for Health Care Attachments Transactions and Electronic Signatures, and Modification to Referral Certification and Authorization Transaction Standard.
The AHA is appreciative of the Department of Health and Human Services (HHS) issuing a rule to standardize the attachments processes, the lack of which has been a significant source of administrative complexity and burden for hospitals and other providers. We believe that standardization of the transmission of clinical data to support claims and prior authorizations could greatly reduce the proliferation of inefficient manual processes used today and eliminate unnecessary processing delays.
Specifically, the AHA is largely supportive of the proposal to standardize claims attachments under the Health Insurance Portability and Accountability Act (HIPAA). This standard has the potential to improve the timeliness of patient billing, as well as provider cash flow, by reducing processing times between when a claim is submitted and a health insurer issues payment. At a time when several of the nation’s largest health insurers are billions of dollars behind on payments to hospitals and providers, and hospitals’ finances are in a precarious state, cutting down on processing times could help alleviate some of the financial strain that many of our members are facing.
The AHA recommends adoption of the proposed standard for claims attachments to help improve claims processing and eliminate unnecessary burdens on providers.
The AHA remains extremely supportive of a standardized approach to processing prior authorizations among health plans. As we have stressed previously, inefficient prior authorization processing creates delays in patient care, increases administrative waste and contributes to clinician burnout. However, the AHA believes that the specific standard proposed for prior authorization attachments is inconsistent with the recently released Centers for Medicare & Medicaid Services (CMS) standard for prior authorizations. Therefore, we are concerned that the lack of harmonization between the regulations could limit the intended improvements for which each rule was designed. As a result, the AHA recommends that HHS refrain from proceeding with the proposed prior authorization implementation standard and instead pursue naming the technology established under the CMS proposed rule as the HIPAA standard for submission of clinical information for prior authorizations.
See the following PDF for our detailed comments.