More Regulatory Comments

RRC responded to CMS’ Request for Information (RFI) about additional data collection that may be useful with respect to the MA program. In the comments RRC emphasized that additional data collection from MA plans can provide additional insight into the impact of prior authorization.

Comment letter to the CMS Administrator on CMS’ Prior Authorization Demonstration for Ambulatory Surgical Center Services would require Ambulatory Surgical Centers to obtain prior authorization before providing certain surgical procedures. RRC provided several questions to CMS about this demonstration and expressed concerns regarding the proposed information collection activity.

Comment letter to the CMS Administrator on Contract Year 2025 Policy and Technical Changes to the Medicare Advantage Program proposed rule. This proposed rule includes several provisions related to prior authorization. RRC made recommendations to improve the rule to better protect patients and reduce physician burden relating to prior authorization requirements.

Comment letter to the CMS Administrator on electronic prior authorization rule supporting provisions that align with the Seniors’ Timely Access to Care Act and recommended improvements to transparency requirements and decision timeframes.

Comment letter to the CMS Administrator on Contract Year 2024 Policy and Technical Changes to the Medicare Advantage Program proposed rule. This proposed rule would set landmark guardrails around the use and abuse of utilization management tools including prior authorization in the Medicare Advantage program.

Comment letter to the National Coordinator for Health Information Technology on the Electronic Prior Authorization Standards, Implementation Specifications, and Certification Criteria (the “e-PA RFI”). This RFI gave RRC the opportunity to make recommendations about how ONC could assist in addressing the overuse and abuse of prior authorization.

Comment letter to the CMS Administrator on Contract Year 2023 Policy and Technical Changes to the Medicare Advantage program proposed rule. This proposed rule includes a request for information about the impact on prior authorization requirements that mandate prior approval for post-acute services.

Letter sent by 29 Senators to CMS Administrator requesting an update on CMS’ recommended next steps for improving and streamlining prior authorization processes. CMS’ support is critical for Congress to pass the Improving Seniors’ Timely Access to Care Act.

Comment letter to CMS Administrator on the 2022 PFS Proposed Rule. The proposed rule would further delay the implementation of the Appropriate Use Criteria (AUC) Program until the January 1 following the end of the COVID-19 Public Health Emergency.

Comment letter to CMS Administrator and CMS Administrator-Designate to implement the e-PA Rule. The proposed rule reflects some of the principles in the Seniors Act, but it excludes Medicare Advantage plans from the scope of the rule.

Comment letter to CMS Administrator on the prior authorization (PA) Proposed Rule. This rule would place new requirements on certain “Impacted Payers” to improve the electronic exchange of data through standards-based API and streamline processes related to Prior Authorization.

Comment letter to CMS Administrator on the Medicare Advantage (MA) advance notice of methodological changes for Contract Year 2022. The proposed rule does not include a prior authorization-related measure on the display page nor does it include the need to focus on Medicare Advantage Organizations’ performance with respect to prior authorization.

The House Small Business Committee letter to CMS Administrator on prior authorization. The letter urges CMS to instruct Medicare Advantage and Part D prescription drug plans to waive their prior authorization requirements for the duration of the COVID-19 national emergency.

Letter to Insurance Commissioners requesting that all health plans licensed in each state waive prior authorization requirements for all health services for the duration of the national emergency.

Letter to CMS Administrator requesting wavier of Medicare Advantage prior authorization requirements during the COVID-19 national emergency.

Comment letter on CMS Services’ Patients over Paperwork Request for Information. RRC provided information about how prior authorization is burdensome and delays care and gave recommendations on actions CMS should take to reduce the administrative burden association with prior authorization.

Comment letter on the Centers for Medicare & Medicaid Services’ Advance Notice of Methodological Changes for Calendar Year (CY) 2019 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2019 Call Letter (“Draft Call Letter”). The letter recognizes the need for Medicare Advantage Organizations’ to make prior authorization processes and requirements transparent and adhered to regulatory timeframes and appeals procedures.

Congressional letter led by Representatives David P. Roe (R-TN) and Ami Bera (D-CA) to the CMS Administrator. The letter discusses how prior authorization creates barriers to timely access to care, and requests that CMS act to improve how prior authorization works under Medicare Advantage.

Letter to CMS Administrator outlining four actions that CMS should take to address issues with prior authorization. The actions outlined in the letter would improve prior authorization in Medicare Advantage plans through CMS providing guidance, standardization, data collection, and oversight measures.

Comment letter to CMS on Paperwork Reduction Act. In this notice CMS proposed to add 18 new data elements to the reporting requirements applicable to Organization Determinations and Reconsideration.

Letter to CMS Administrator on prior authorization under Medicare Advantage and the Patients over Paperwork initiative. The letter urges CMS to issue guidance and oversight on Medicare Advantage Organizations’ prior authorization requirements to reduce the unnecessary administrative burden.