Comment on CMS-2026-1255-0001
Association for Behavioral Health and WellnessSupportAdvocacy
Summary: The Association for Behavioral Health and Wellness (ABHW) supports the goals of improving medication access and streamlining prior authorizations but expresses concerns regarding the feasibility of the proposed turnaround times. They recommend "stopping the clock" for incomplete requests, exempting bundled behavioral health services from the 24-hour drug turnaround time, and limiting payer-to-payer data sharing to active transitions to protect patient privacy.
Dear Dr. Oz and Assistant Secretary Keane:
The Association for Behavioral Health and Wellness (ABHW) appreciates the opportunity to submit comments to the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) on Interoperability Standards and Prior Authorization for Drugs Proposed Rule.
ABHW is the national voice for payers managing behavioral health insurance benefits. Our member companies provide coverage to 200 million people in both the public and private sectors to treat mental health (MH), substance use disorders (SUDs), and other behaviors that impact health and wellness. Our organization aims to increase access, drive integration, support prevention, raise awareness, reduce stigma, and advance evidence-based treatment and quality outcomes. Furthermore, our policy work aims to ensure that physical and behavioral health care is integrated and coordinated. ABHW is committed to improving outcomes in whole-person care for all individuals and communities. We believe access to comprehensive, evidence-based MH and SUD services is critical to enhancing patients’ health and overall well-being.
ABHW supports CMS's goal of improving timely access to medications, streamlining the prior authorization process, and expanding the availability of electronic prior authorization.
Please see more details in our attached letter.
Sincerely,
Debbie Witchey, MHA
President and CE
