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Comment Letter: Proposed Rule on Interoperability Standards and Prior Authorization for Drugs

In a letter to U.S. Department of Health and Human Services Secretary Robert F. Kennedy, Jr., the Medicaid and CHIP Payment and Access Commission (MACPAC) commented on proposed rulemaking on interoperability standards and prior authorization for drugs. This proposed rule includes a number of provisions to implement interoperability standards for impacted payers, including Medicaid and the State Children’s Health Insurance Program (CHIP), to improve the exchange of data and information on prior authorization (PA) related to prescription drugs.

In the letter, MACPAC shared insights from an extensive body of work on PA and denials and appeals in the Medicaid program, for which the Commission has made recommendations for increased transparency and oversight. The Commission supports efforts in this proposed rule to improve transparency into the PA process and report data on the volume and outcomes of PA decisions for both drugs and non-drug items and services. The Commission asks CMS to consider reporting these data at a more granular level to better monitor PA outcomes for specific populations and services. The letter concludes with a technical consideration regarding the PA decision timelines for drugs that are provided as part of, or incident to and in the same setting as, certain non-drug items and services.