Comment on CMS-2026-1255-0001
HealthHIVSupportAdvocacy
Summary: HealthHIV, a national nonprofit, supports the proposed rule to make prior authorization more electronic, transparent, and transferable across payers to reduce delays and improve continuity of care. However, they emphasize that electronic processing alone is not a solution for all drugs and urge CMS to ensure the policy actually reduces real-world medication disruptions and provides clear, actionable denial reasons.
Executive Summary: HealthHIV supports CMS making prior authorization more electronic, transparent and transferable across payers. That includes faster electronic processing, clearer denial reasons and better payer-to-payer exchange when someone changes coverage. But making prior authorization faster or more electronic does not mean prior authorization is appropriate for every drug. For HIV treatment, HIV prevention and other medications where delay can undermine treatment, prevention or continuity of care, the first question should be whether prior authorization should be used at all.