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AHIP Comments on Proposed Rule for Data Exchange and Prior Authorization

Comment Letter

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Published on Jan 5, 2021

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AHIP submitted comments to the Centers for Medicare & Medicaid Services (CMS) on a proposed rule focused on the exchange of health data and processes related to prior authorization for Medicaid, CHIP and individual market plans.

AHIP applauds increased transparency and accessibility of actionable, personalized health information to support Americans as they make their health care decisions. Even as we work together with health care leaders and providers across the nation to fight the COVID-19 crisis, our members are hard at work implementing the consumer data-sharing provisions of the Interoperability and Patient Access Final Rule (Interoperability Rule) and the Transparency in Coverage Final Rule (Transparency Rule).

We further support the goal of seamlessly sharing information between health care providers and health insurance providers. Improving access to meaningful information can help everyone to realize the full benefits of health information technology.

While we support many of the steps outlined in this Proposed Rule, we believe the Proposed Rule is flawed and must oppose its implementation in this form at this time for multiple reasons, including:

  • competing priorities and demands of the COVID-19 crisis,
  • truncated comment period,
  • unrealistic effective dates,
  • ongoing implementation of the Interoperability Rule,
  • ongoing implementation of the Transparency Rule,
  • lack of fully mature standards and implementation guides (IG),
  • lack of robust privacy standards applicable to third-party application (app) developers,
  • lack of concomitant obligations on electronic health record (EHR) vendors and healthcare providers to connect to the proposed technology requirements, and
  • lack of specified funding to underwrite the costs of implementation.

Our comments and recommendations regarding the Proposed Rule reflect AHIP’s commitment to develop policy solutions that will support a more consumer-focused market, ensure access to meaningful, actionable information, and promote quality and affordability. AHIP and its members look forward to working with HHS to further refine these proposals and to determine an appropriate timeframe for implementing these provisions to advance greater interoperability between health insurance providers and both consumers and health care providers.