On Jan. 27, the AANS and the CNS joined the Alliance of Specialty Medicine (ASM) in sending a letter to the Centers for Medicare & Medicaid Service (CMS) providing feedback on proposed policy changes for Medicare Advantage (MA) and Part D prescription drug plans and their impact on access to specialty medical care. In the letter, the AANS, CNS, and ASM:
- Urge CMS to use its oversight and enforcement authority to conduct program audits to identify MA plans that fail to comply with CMS’ regulations and institute enforcement measures, including financial penalties, and where plan behavior is more egregious, termination from the MA program altogether.
- Ensure the use of prior authorization does not disadvantage underserved populations and institute metrics for the annual health equity analysis of the use of prior authorization that thoroughly measure the extent and impact of the burdensome requirements that often result in delay or denial of appropriate care.
- Implement measures to bolster MA plan access to specialty care, including requiring plans to maintain accurate, real-time provider directories that include specialty and subspecialty designations.
- Establish a star measure system to encourage MA plans to maintain an adequate network of specialty and subspecialty providers as “in-network.”
- Improve the process for medical record requests, clarify the nature of the requests, provide reasonable deadlines and reimburse practices fairly for completing medical record requests.
A letter from the American Medical Association (AMA) in response to the proposed rule is available here.
