AHA Comments on CMS’ Interoperability and Prior Authorization Proposed Rule

June 15, 2026

The Honorable Robert F. Kennedy Jr.
Secretary
Department of Health and Human Services
200 Independence Ave. SW
Washington, DC 20201

Mehmet Oz, M.D.
Administrator
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244-1850

Thomas Keane, M.D., MBA
National Coordinator for Health Information Technology
Department of Health and Human Services
330 C St. SW, 7th Floor
Washington, DC 20024

Re: CMS‑0062‑P, Medicare and Medicaid Programs; Patient Protection and Affordable Care Act; Interoperability Standards and Prior Authorization for Drugs for Medicare Advantage Organizations, Medicaid Managed Care Plans, State Medicaid Agencies, Children’s Health Insurance Program (CHIP) Agencies and CHIP Managed Care Entities, and Issuers of Qualified Health Plans on the Federally-Facilitated Exchanges

Dear Secretary Kennedy, Administrator Oz and National Coordinator Keane:

On behalf of our nearly 5,000 member hospitals, health systems and other healthcare organizations, and our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 healthcare leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS’) proposed rule titled “Interoperability Standards and Prior Authorization for Drugs.”

Hospitals and health systems are committed to CMS’ ongoing efforts to reduce administrative burden, advance interoperability and improve patients’ access to timely, medically necessary care. Prior authorization remains one of the most significant administrative challenges facing the healthcare delivery system, consuming substantial clinical and operational resources while frequently interfering with patient care. As prior authorization requirements persist across payers, services and benefit types, providers must navigate complex, fragmented and manual processes that detract from care delivery and strain an already overextended workforce. These long-standing challenges underscore why CMS’ proposed rule is both timely and necessary, offering an opportunity to advance more streamlined, consistent and efficient prior authorization processes across the healthcare system.

While the AHA strongly supports CMS’ goal of modernizing prior authorization and extending interoperability requirements, the effectiveness of these policies will depend on thoughtful implementation that aligns with clinical workflows, ensures consistent payer behavior and meaningfully reduces administrative burden for providers. To that end, we urge CMS, Health and Human Services (HHS) and the Office of the National Coordinator for Health Information Technology (ONC) to adopt the following key policy updates:

• Ensure timely and consistent prior authorization decisions across all services. CMS should adopt uniform decision timeframes of 72 hours for standard requests and 24 hours for expedited requests across both drug and non-drug items and services to prevent unnecessary delays in care.
• Strengthen transparency and usability of prior authorization metrics. CMS should require service-level reporting, standardized public posting and centralized access to plan data to ensure that patients, providers and regulators can meaningfully evaluate plan performance.
• Establish a centralized, standardized repository of payer API endpoints. CMS should require machine-readable, accurate and timely publication of endpoint information to support scalable implementation of electronic prior authorization workflows.
• Advance a deliberate transition from X12 to FHIR-based prior authorization. HHS should replace the X12 278 transaction with the FHIR-based Prior Authorization API while adopting a phased implementation timeline and ensuring interoperability standards are operationally independent from legacy constructs.
• Ensure any transition to FHIR-based eligibility transactions is evidence-based and does not disrupt existing workflows. CMS should retain the current 270/271 transaction until FHIR-based alternatives are proven reliable at scale.
• Promote standardized, predictable documentation workflows for prior authorization. CMS should establish Documentation Templates and Rules (DTR) as the primary documentation approach, limiting reliance on attachment-based processes that increase burden and variation.
• Strengthen implementation oversight and accountability for payer APIs. CMS should require robust conformance testing, transparency into results and validation of real-world usability to ensure that APIs deliver meaningful operational improvements.
• Support a staged, coordinated implementation of interoperability standards. CMS and ONC should align compliance timelines, testing readiness and version transitions to prevent fragmentation and ensure consistent adoption across the market.

Thank you for your attention to our comments. We particularly appreciate CMS’ and ONC’s thoughtful proposals to alleviate provider burden and improve patient care and access. We urge CMS to finalize the proposed rule with modifications as recommended above. Our detailed comments are attached. The AHA is pleased to be a resource on these issues and welcomes any opportunity to provide any additional insight that would be helpful to the agency as you plan for future rulemaking. Please contact me if you have any questions, or feel free to have a member of your team contact Andrea Preisler, AHA senior associate director for administrative simplification policy, at apreisler@aha.org.

Sincerely,

/s/

Ashley Thompson
Senior Vice President
Public Policy Analysis and Development

Download the full letter PDF.