Reducing Provider and Patient Burden by Improving Prior Authorization Processes, and Promoting Patients’ Electronic Access to Health Information for Medicaid Managed Care Plans


 The National Health Council (NHC) appreciates the opportunity to provide comments on the Centers for Medicare and Medicaid Services’ (CMS) proposed rule refining prior authorization processes in Medicaid and Children’s Health Insurance Program (CHIP), and for issuers of qualified health plans on the Federally facilitated exchanges (the Proposed Rule). 

Created by and for patient organizations 100 years ago, the NHC brings diverse organizations together to forge consensus and drive patient-centered health policy. We promote increased access to affordable, high-value, sustainable health care. Made up of more than 140 national health- related organizations and businesses, the NHC’s core membership includes the nation’s leading patient organizations. Other members include health-related associations and nonprofit organizations including the provider, research, and family caregiver communities; and businesses representing biopharmaceutical, device, diagnostic, generic drug, and payer organizations. 

The NHC appreciates CMS’ efforts to reduce longstanding inefficiencies in the health care system, including those associated with limited data sharing, and overly burdensome and opaque prior authorization processes. 

Our comments focus on these important areas: 

  • Reducing provider burden and patient delays associated with prior authorization (PA) processes; 
  • Exclusion of prescription drugs and covered outpatient drugs; 
  • Medicare Advantage; and 
  • Balancing access to health information with patient privacy. 

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