Comment on CMS-2026-1255-0001

Re: CMS-0062-P, 2026 CMS Interoperability Standards and Prior Authorization for Drugs (91 FR 19890) EVRESA LLC (Enterprise Verification - Regulated E-Settlement Architecture) submits the attached public comment package on CMS-0062-P, RIN 0938-AV44: a foundational comment, three RFI responses, and an Operational Impact Statement on independent community pharmacy. EVRESA is an AI-governance infrastructure developer building CATN, the Care Access Trust Network by EVRESA, a governance and decision-provenance layer for prior authorization. EVRESA submits this comment as a developer of governance infrastructure, not as a payer or provider; our perspective is architectural. EVRESA strongly supports extending electronic prior authorization to drugs, aligning decision timeframes, and requiring a specific reason for each denial. EVRESA writes to identify one implementation gap that will determine whether these gains are durable: the proposed rule standardizes the transaction of a prior authorization decision, but not the governance proof layer needed to establish accountability for that decision where automated or AI-enabled tools are used. To meet 72-hour and 24-hour timeframes, impacted payers and technology partners may increasingly place automated, rules-based, or AI-enabled systems in the decision loop. A specific denial reason is necessary, but it is not sufficient by itself. A denial reason does not establish who or what rendered the decision, whether AI contributed, what evidence was reviewed, under whose authority the decision was made, or whether a qualified human remained accountable at the decision point. Without governance-layer controls, a denial reason can become a machine-generated field attached to an unaccountable automated decision. EVRESA recommends that CMS recognize, in the final rule preamble or subsequent implementation guidance, privacy-preserving governance-layer controls above the transaction layer standardized by CMS-0062-P. These controls should include decision provenance, human-authority attestation, tamper-evident audit records, evidence-chain integrity, and a verifiable chain of custody for decision evidence. First, CMS should encourage decision provenance records for drug prior authorization determinations where automated or AI-enabled tools are used, including a structured, machine-verifiable record of which system rendered or supported the decision, whether AI contributed, what evidence was reviewed, and which human authority was accountable for the outcome. Second, CMS should encourage denial reasons to be bound to provenance records where feasible, so appeals, audits, and oversight can verify that a denial was not an unreviewed automated action. Third, in response to RFI III.B on Increasing Health Care Resiliency, CMS should treat the integrity and auditability of the prior authorization decision record as a resiliency control. Resiliency is not only uptime; it is the ability to prove, after the fact, that decisions affecting patient access were made under valid authority through a verifiable chain of custody for decision evidence. Fourth, CMS should encourage testable governance outcomes. Provenance, human-authority, evidence-chain, and tamper-evident audit controls should be verifiable through implementation testing, not self-attestation alone. These recommendations do not require CMS to mandate EVRESA, CATN, or any specific vendor, platform, ledger, or architecture. They define a vendor-neutral outcome: where automated or AI-enabled tools are used, every prior authorization decision should be attributable, authority-bound, evidence-linked, privacy-preserving, and auditable. EVRESA's design pattern operationalizes this principle as Human Authority, Enforced at Machine Speed, and is offered as one reference model among many possible implementations. As CMS modernizes prior authorization to protect patient access, the same automation that creates speed also creates a new governance risk: speed without accountability. Governance-layer controls allow CMS and the healthcare ecosystem to capture the benefits of automation while preserving the human authority, evidence integrity, privacy, and auditability that make prior authorization decisions trustworthy. Respectfully submitted, John Gray Rodriguez Founder & Chief Executive Officer EVRESA LLC Care Access Trust Network (CATN) by EVRESA File Code: CMS-0062-P Docket No. CMS-2026-1255