Comment on CMS-2026-1255-0001

ONE CANCER PLACE The Address for CancerWorld Denver, Colorado | onecancerplace.org | erika@onecancerplace.org | 303.780.9111 JUNE 15,2026 To: Centers for Medicare & Medicaid Services (CMS) Attention: Docket ID CMS-2026-1255 Reference: RFI for Prior Authorization and Access to Laboratory Testing (Section III.E of CMS-0062-P) Submission Portal: Regulations.gov Re: Comment on RFI for Prior Authorization and Access to Laboratory Testing To Whom It May Concern: My name is erika hanson brown. I’m a long-term cancer survivor, and I’m the Founder and First KAPA — KAPA-in-Chief — of One Cancer Place, a nonprofit built around one job: closing the gaps in the cancer experience that no one else is responsible for closing. I’m writing about a gap that sounds like an administrative footnote and feels, to the person living it, like the floor dropping out from under them. Here’s the gap: a doctor orders a blood test. The patient shows up. The blood is drawn. And then — depending entirely on paperwork the patient never sees and has no control over — that blood may or may not “count.” Many health plans require prior authorization to be finalized on or before the exact date a specimen is collected. That is not how labs work. Blood gets drawn before the lab receives it, and authorizations get resolved after the fact — if at all. This hits hardest on the high-complexity biomarker and specialty tests that matter most to people with cancer and rare diseases, where time is everything. When the dates don’t line up, the specimen doesn’t get processed. It sits. It’s rejected. It’s discarded once it ages out of its viability window. And the patient — who did everything right — gets a phone call asking them to come back and do it again. I’ve been that patient. I know what it does to a person to be told, after the blood is already drawn, that it might not count, and that they need to come back and do it again. For someone fighting cancer, “again” is never just another needle. It’s another day without an answer. Another delay before a treatment decision can be made, a treatment plan can be adjusted, or a clinical trial door opens or closes. Waiting for results is already one of the hardest parts of this disease. The system should not be adding to that wait. The people who pay the highest price for this can least afford it. Rural patients. Low-income families. People who don’t live anywhere near a major cancer center. A repeat blood draw isn’t a minor inconvenience for them — it’s a missed day of work, a tank of gas, a ride they had to ask for, childcare they had to find, all over again, while they’re already sick. For these patients, a timing mismatch in a prior authorization system isn’t an administrative hiccup. It’s a barrier to care. I urge CMS to require health plans to: •Allow retroactive approvals — let prior authorization be submitted and approved after specimen collection, when the lab had no control over the timing of the draw. •Prohibit timing-based denials — a medically necessary lab test should never be denied or delayed solely because the authorization wasn’t finalized on or before the collection date. •Eliminate redundant testing — if a viable specimen already exists and is ready for analysis, patients should never be asked to repeat a blood draw because of a paperwork mismatch. •Establish expedited pathways — oncology and other time-sensitive diagnostics need faster prior authorization turnaround, full stop. •Standardize documentation — health plans should accept standard clinical documentation from physicians and labs to verify medical necessity, without inventing new hurdles plan by plan. •Protect patients financially — when the patient, physician, and lab all acted in good faith, the patient should never be the one left holding a surprise bill. This matters even more as early detection and screening tests become a bigger part of how cancer is found and treated. The entire value of early detection is time — finding something sooner so a person can act on it faster. A prior authorization system built around specimen-collection dates quietly cancels out that advantage before it ever reaches the patient. If we’re serious about early detection, the system around it has to move at the speed of biology, not the speed of paperwork. Patients are not asking for special treatment. They’re asking for the system to catch up to where they already are — needle in arm, doing exactly what they were told to do, waiting for an answer that shouldn’t be held hostage by a date on a form. erika hanson brown Founder & First KAPA — KAPA-in-Chief One Cancer Place Denver, Colorado erika@onecancerplace.org | 303.780.9111