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Joint Letter on PA Attachment Standards

Comment Letter

Follow-up on Notice of Proposed Rule Making Regarding Adoption of Standards for Prior Authorization Attachments

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Published on Jul 27, 2023

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As national organizations representing physicians, hospitals, and health insurance plans, we sincerely appreciate efforts by the Centers for Medicare & Medicaid Services (CMS) to reduce administrative burdens and costs in our health care system through the December 2022 Notice of Proposed Rule Making (NPRM) regarding adoption of electronic transaction standards for health care attachments. We also applaud CMS’ focus on reforming prior authorization (PA) and share the Administration’s goals of ensuring timely access to care for patients and minimizing manual paperwork for all health care stakeholders. However, our organizations urge CMS to not proceed with implementing the PA attachment standards provisions of the NPRM due to conflicting regulatory proposals that would set the stage for multiple PA electronic standards and workflows and create the very same costly burdens that administrative simplification seeks to alleviate.