Comment on CMS-2026-1255-0001

On behalf of the American Academy of Family Physicians (AAFP), which represents 124,500 physicians and medical students nationally, I write in response to the Centers for Medicare and Medicaid Services' (CMS) and Office of the National Coordinator for Health Information Technology’s (ONC) proposed rule regarding advancing interoperability and improving prior authorization processes. The AAFP appreciates the Departments introducing proposals to improve the electronic exchange of health care data and streamline prior authorization processes, including expanding these processes to medications. Prior authorization requirements cause barriers to care, delayed care for enrollees, and impose significant administrative burdens on physicians. We applaud CMS and ONC for their thoughtful collaboration throughout the development of this proposed rule, as well as for continuing to include Medicare Advantage organizations in the list of impacted payers, consistent with previous AAFP advocacy. Thank you for the opportunity to provide written comments on this important topic and its potential impact on primary care access in the U.S. We stand ready to collaborate with the agencies and other stakeholders to advance meaningful reform, including reducing the overall volume of prior authorizations, continuing to standardize clinical criteria, and strengthening enforcement of payer compliance with established requirements.