Comment on CMS-2026-1255-0001

I am writing on behalf of the Ruby A. Neeson Diabetes Awareness Foundation as a patient advocate to urgently request that CMS protect patients from critical care delays and denials caused by rigid prior authorization requirements for laboratory testing. We take issue with the detrimental impact of prior authorization barriers on diabetes care. Aside from significantly increasing the risk of severe complications and care discontinuity, these barriers impose unfair financial and psychological strains on vulnerable populations. We are grateful to CMS for its ongoing efforts to modernize and streamline the prior authorization process, and we deeply appreciate the opportunity to provide this feedback. To better align insurance policies with real-world clinical workflows, we request that CMS mandate that health plans: •Allow Retroactive Approvals. Ensure that necessary lab tests conducted during urgent care visits are eligible for coverage without risk of arbitrary retroactive denial. •Prohibit Timing-Based Denials. Prevent insurers from rejecting claims solely due to strict calendar or timing constraints, which often conflict with individualized diabetes care. •Eliminate Redundant Testing. Require coordinated care networks to accept recent, comprehensive laboratory results to avoid unnecessary, repetitive blood draws. •Establish Expedited Pathways. Create swift, streamlined approval processes for medically necessary, time-sensitive continuous glucose monitoring and laboratory data. •Protect Patients Financially. Cap out-of-pocket costs and protect patients from unexpected billing when prior authorization delays or administrative errors occur Individuals managing diabetes require timely, continuous access to laboratory data. Prior authorization frameworks must promote patient health rather than function as administrative barriers. Thank you for your consideration of these critical recommendations. Sincerely, Mutima Jackson-Anderson, Executive Director Ruby A. Neeson Diabetes Awareness Foundation