Comment on CMS-2026-1255-0001

Premier Inc. appreciates the opportunity to submit comments on the Medicare Program; Interoperability Standards and Prior Authorization for Drugs for Medicare Advantage Organizations, Medicaid Managed Care Plans, State Medicaid Agencies, Children's Health Insurance Program (CHIP) Agencies and CHIP Managed Care Entities, and Issuers of Qualified Health Plans on the Federally-Facilitated Exchanges), CMS-0062-P. Premier appreciates the Centers for Medicare & Medicaid Services (CMS)’ ongoing commitment to improving access to care and enabling better data exchange among providers, patients and payers. In our detailed comments below, Premier specifically recommends that CMS: •Finalize its proposed policy to require that impacted payers support electronic prior authorization (ePA) for all drugs that require prior authorization which would align with non-drug ePA policies. •Finalize the proposed timeline for drug prior authorization (requiring payers to respond within 72-hours for standard requests, and 24 hours for urgent requests) for Qualified Health Plan (QHP) issuers and shorten the existing timelines for non-drug prior authorization to advance greater alignment of prior authorization timeframes across payer types. •Continue its work on encouraging payer transparency around reasons for denials by developing a clear and enforceable definition of “specific reason.” CMS should prohibit the use of vague or non-actionable denial language, so providers and their patients have adequate feedback from payers to address prior authorization claim denials. •Continue advancing Fast Healthcare Interoperability Resources (FHIR)-based interoperability standards to improve transparency, reduce administrative burden and streamline prior authorization, while providing adequate transition time, clear technical guidance, and flexibility given current limitations in implementation and data standards. •Modernize HIPAA prior authorization FHIR-based standards while providing adequate implementation timelines, clear guidance and transitional flexibility to avoid disrupting workflows or patient access to care. •Finalize its proposed policy to require impacted payers to annually report standard and expedited prior authorization metrics for drugs and establish a standardized, machine readable and minimally burdensome approach. •Advance electronic event notification for value-based care and care coordination through incentives, technical support and flexible policy levers rather than unfunded mandates. •Work with stakeholders to strengthen healthcare cyber resilience through specific, adaptable and maturity-based standards supported by funding and operational assistance.