Comment on CMS-2026-1255-0001
National Psoriasis FoundationSupportAdvocacy
Summary: The National Psoriasis Foundation supports the proposed rule to improve electronic prior authorization and interoperability for drugs, noting it will benefit patients with chronic diseases. They recommend specific refinements to ensure the process is patient-centered, including maintaining short decision-making timelines, improving the clarity of denial communications, and creating a standardized step therapy exceptions process.
The National Psoriasis Foundation (NPF) appreciate the opportunity to comment on the proposed rule. We believe that several aspects of the proposal will improve the prior authorization process for patients living with chronic diseases like psoriatic disease. We recommend CMS finalize these policies with specific patient-centered refinements that are described in further detail in the attached document, including:
1. Clarifying that the goal of electronic prior authorization is to create a more timely, predictable, and navigable process, not merely a digitized one
2. Implementing exception mechanisms narrowly, transparently, and temporarily
3. Maintaining the proposed decision-making timelines
4. Ensuring that denial communications are sufficiently specific, timely, and operationally useful
5. Ensuring the electronic prior authorization process supports patient continuity of care
6. Creating a suite of reportable metrics that measure improved patient-centered care
7. Requiring plans to implement a standardized step therapy exceptions process that recognizes previous payer’s determination
8. Adopting patient-centered prior authorization rules tailored to laboratory testing workflows