January 4, 2021
Seema Verma, Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-9123-P
P.O. Box 8016
Baltimore, MD 21244-8016
Re: RIN 0938-AT99 Medicaid Program; Patient Protection and Affordable Care Act;
Reducing Provider and Patient Burden by Improving Prior Authorization Processes, and
Promoting Patients’ Electronic Access to Health Information for Medicaid Managed Care
Plans, State Medicaid Agencies, CHIP Agencies and CHIP Managed Care Entities, and
Issuers of Qualified Health Plans on the Federally-facilitated Exchanges; Health
Information Technology Standards and Implementation Specifications (the “PA Proposed
Rule” or “Proposed Rule”)
Dear Administrator Verma:
The Regulatory Relief Coalition (RRC) is pleased to have the opportunity to comment on the prior
authorization (PA) Proposed Rule. The RRC is a group of national physician specialty organizations
advocating for regulatory burden reduction in programs administered by the Centers for Medicare and
Medicaid Administration (CMS) so that physicians can spend more time treating patients. Most recently,
we have focused on common-sense reform of Medicare Advantage Organizations’ (MAOs’) use of PA.
Our aim is to ensure that PA is not a barrier to timely access to care for the patients we serve.
The PA Proposed Rule would place new requirements on certain “Impacted Payers,” including state
Medicaid and Childrens Health Insurance Program (CHIP) fee-for-service (FFS) programs, Medicaid
managed care plans, CHIP managed care entities, and Qualified Health Plan (QHP) issuers on the
Federally-facilitated Exchanges (FFEs) to improve the electronic exchange of health care data through
standards-based Application Programming Interfaces (API), and to streamline processes related to PA.
The RRC believes that the PA Proposed Rule is a step forward in reigning in the mounting burden of
PA processes. We are particularly gratified that the PA Proposed Rule reflects some of the principles of
included in H.R. 3107, the Improving Seniors’ Timely Access to Care Act of 2019. This important
legislation establishes a blueprint for the reform of MA Plan PA processes, and at the close of the 116th
Congress, had garnered the bipartisan support of 280 members of the House of Representatives. We
applaud CMS for adopting the principles outlined in H.R. 3107 and look forward to working with the
Agency to further refine and expand federal oversight over health plans’ PA practices.
Read full letter here
