13 Mar HCTTF Provides Input to CMS on the Advancing Interoperability and Improving Prior Authorization Processes Proposed Rule
The Health Care Transformation Task Force submitted comments to CMS on the Advancing Interoperability and Improving Prior Authorization Processes Proposed Rule. The Task Force generally supports the Proposed Rule’s policy goals and views improving interoperability and prior authorization as critical to broader health system transformation. However, some HCTTF members noted concerns with the lack of well-defined data standards for prior authorization information, maturity of existing implementation guidelines, and flexibility in CMS’ approach to defining technical standards- all issues that could hamper the successful implementation of the proposed rule. The Task Force positions on the specific sections of the proposed rule are summarized below:
- Patient Access API: The Task Force generally supports CMS’ proposal for updates to the currently mandated patient access API to expand patient access to and transparency around decisions impacting their care.
- Provider Access API: The Task Force generally supports CMS’ proposal for a Provider Access API that makes patient data available to providers in accordance with the wishes of enrollees. HCTTF did note member feedback encouraging CMS to consider the following issues: API standards should indicate whether a prior authorization request is standard or urgent, alternatives to opt-in and opt-out policies may be needed to avoid patients unnecessarily restricting sharing of all data, and the need for CMS to pair payer requirements with policies that promote provider uptake of the Provider Access API should be explored.
- Payer-to-Payer Data Exchange: The Task Force generally supports CMS’ proposal for a Payer-to-Payer data exchange for enrollees that are covered by multiple payers or transitioning between payers. The Task Force also supports improving data interoperability across all payers including Original Medicare, and has proposed that CMS develop an API to facilitate bi-directional data exchange between Original Medicare and Medicare Advantage Plans.
- Improving Prior Authorization Process: The Task Force generally supports the goals of the proposed PARDD API requirements, but members noted potential issues and opportunities with requirements regarding PA time frames and metrics. CMS should consider providing additional clarity on time frames, incentivizing providers to adopt electronic prior authorization, engaging with impacted payers to address concerns about publicly reported PA metrics, and addressing areas of concern where PA policies impact clinical care.
The Task Force also responded to two requests for information on accelerating the adoption of standards related to social risk factor data and electronic exchange of behavioral health information.