Comment on CMS-2026-1255-0001

The ALS Association appreciates the opportunity to comment on CMS’s proposed rule to modernize prior authorization (PA) and interoperability requirements, including the extension of these requirements to prescription drugs. Our mission is to make ALS livable until it is cured by advancing research, supporting people living with ALS with innovative equipment and services, and advocating for policies that ensure timely access to high quality care. The ALS Association commends CMS for prioritizing prior authorization reform and recognizing the significant impact that streamlined and modernized processes can have on patient outcomes and provider efficiency. By addressing longstanding administrative burdens and avoidable delays, CMS demonstrates a meaningful commitment to strengthening the health care system for individuals with complex medical needs, including people living with ALS. These reforms better equip providers to deliver timely, coordinated care and reduce barriers that undermine access to treatment and quality of life. Timely access to care is essential for people living with ALS, a rapidly progressive disease that requires prompt and uninterrupted medical intervention. Delays in authorizing medically necessary services, equipment, or medications can result in irreversible loss of function, increased caregiver burden, and avoidable health complications. Prior authorization policies must therefore be designed to facilitate—rather than impede—access to the care and supports that enable individuals with ALS to maintain independence and manage symptoms effectively. CMS has an important opportunity to ensure that prior authorization functions as a tool for appropriate care management rather than an obstacle to medically necessary treatment. Continued investment in electronic prior authorization and interoperability can reduce duplicative paperwork, expedite decision‑making, and improve communication between providers and plans. These improvements are particularly critical for ALS care, where clinical needs are urgent, ongoing, and best addressed through coordinated specialty care. The ALS Association urges CMS to finalize this rule with strong, enforceable protections to safeguard timely and nondiscriminatory access to care. This includes adopting default expedited pathways for ALS‑related services, shortening decision timelines for urgent requests, and supporting utilization management approaches—such as appropriately structured gold‑carding programs—that recognize established provider expertise. Together, these reforms will reduce treatment disruptions, promote effective care coordination, and align utilization management with the realities of progressive and life‑limiting conditions. In closing, the ALS Association strongly supports CMS’s efforts to modernize prior authorization and urges continued improvements that prioritize access, efficiency, and equity for medically complex patients. By implementing these reforms, CMS can strengthen the health care system’s ability to serve individuals with critical medical needs, improve the delivery of ALS care, and ensure that coverage policies support timely, patient centered treatment. We sincerely appreciate CMS’s dedication to addressing the unique challenges faced by people living with ALS and recognizing their urgent healthcare needs.