Medicare and Medicaid Programs: Patient Protection and Affordable Care Act; Interoperability Standards and Prior Authorization for Drugs for Medicare Advantage Organizations, Medicaid Managed Care Plans, etc.

The National Comprehensive Cancer Network (NCCN) supports CMS's proposal to establish more timely and consistent prior authorization notification timeframes to reduce treatment delays in oncology. They also request that CMS require clear, evidence-based rationales for prior authorization denials to help providers submit appropriate documentation and pursue informed appeals.

The Paltown Development Foundation, a nonprofit patient advocacy organization, supports CMS's efforts to modernize and streamline prior authorization processes. They argue that rigid prior authorization creates dangerous delays and denials for medically necessary cancer biomarker testing and urge CMS to implement specific protections to ensure timely patient access.

The Healthy Aging Coalition supports the proposed rule but urges CMS to strengthen it by requiring standardized public posting of prior authorization metrics, establishing a centralized public database, and extending transparency requirements to include Medicare Part D drugs. They also advocate for reporting these metrics by specific service categories to better identify patterns of care denial.

Erika Hanson Brown, representing the nonprofit One Cancer Place, supports the proposed action to modernize prior authorization standards. She argues that current timing requirements for prior authorization cause patients to undergo redundant testing and experience dangerous delays in cancer treatment, and she urges CMS to require retroactive approvals and prohibit timing-based denials.

The Prader-Willi Syndrome Association | USA (PWSA | USA) supports CMS's efforts to modernize prior authorization processes but urges specific protections for patients with rare diseases. They argue that prior authorization delays can lead to dangerous clinical consequences, unnecessary repeated blood draws for patients with behavioral challenges, and significant administrative burdens on families and providers.

The Illinois Public Health Association (IPHA) supports the proposed action but urges CMS to include specific protections to prevent clinical delays caused by rigid prior authorization requirements. They advocate for measures such as allowing retroactive authorization, prohibiting denials based solely on timing, and requiring expedited reviews for oncology-related testing.

America's Essential Hospitals supports the proposed rule to modernize interoperability standards and streamline prior authorizations, particularly for drugs. However, the organization urges CMS to mandate real-time determinations for all services, provide financial support and extended timelines for safety-net hospitals to adopt FHIR standards, and strengthen EHR certification requirements.

EVRESA LLC, an AI-governance infrastructure developer, supports the proposed rule's standardization of electronic prior authorization and compressed decision timeframes. They argue that while the rule modernizes the transaction layer, CMS should also recognize a "governance proof infrastructure" to ensure that automated or AI-enabled decisions remain accountable, human-authorized, and auditable.

The National Infusion Center Association (NICA) supports the proposed rule to implement electronic prior authorization for drugs and improve transparency and decision timeframes. However, they express concern regarding the continued bifurcation of workflows between medical and pharmacy benefits and oppose the removal of formulary information from certain APIs.

The Ruby A. Neeson Diabetes Awareness Foundation supports the effort to modernize prior authorization but requests specific mandates to protect diabetes patients. They argue that CMS should require health plans to allow retroactive approvals, prohibit timing-based denials, eliminate redundant testing, and establish expedited pathways for time-sensitive laboratory data.