Dear Administrator Verma:
The undersigned physician organizations support the Centers for Medicare & Medicaid Services’
(CMS) Patients Over Paperwork initiative and applaud CMS for tackling the challenging issue of
prior authorization (PA) as part of your efforts to reduce administrative burdens in health care.
Physician practices report completing an average of 31 PAs per physician per week. This
workload consumes 14.9 hours (nearly 2 business days) each week of physician and staff time
and reflects time that would be better spent with patients. More importantly, PA is negatively
impacting patient care. Over one-quarter (28%) of physicians report that PA has led to a serious
adverse event (e.g., disability, hospitalization, death) for a patient in their care.
We do, however, have strong concerns that CMS may be focusing on automation as the only
vehicle for implementing PA reforms. We are aware that CMS has invested heavily in the Da
Vinci Project, which leverages technology to facilitate electronic exchange of clinical data by
extracting information from physicians’ electronic health records (EHRs). While Da Vinci holds
promise, there are a series of issues with exclusively relying on technology to address the
burdens of PA. For example, solely concentrating on process automation may set the stage for
increased PA volume because document exchange will be easier and faster. Patient care delays
will continue, as manual review of medical documentation is often required following the
instantaneous electronic exchange of data. Furthermore, Da Vinci will allow payers
unprecedented access to EHRs. Protections are needed to prevent plans from inappropriately
accessing patient information, coercing physicians into using technology (e.g., through
contracts), or interfering with medical decision making. Lastly, Da Vinci represents nascent
technologies that have yet to be widely implemented. Therefore, the costs and the timeframe
availability across EHR vendors remain unclear. Of considerable concern, Da Vinci likely will
not offer relief from PA for small practices in the near future.
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