Secure Electronic Prior Authorization for Part D Drugs
CMS-4189-P
2019-08-20 2019-07-23 2019-07-23 2019-08-20 2019-08-20 2019-08-13
CMS-2019-0090-0042 CMS-2019-0090-0002 CMS-2019-0090-0004 CMS-2019-0090-0029 CMS-2019-0090-0041 CMS-2019-0090-0008
04:00:00 04:00:00 04:00:00 04:00:00 04:00:00 04:00:00
https://api.regulations.gov/v4/comments/CMS-2019-0090-0042 https://api.regulations.gov/v4/comments/CMS-2019-0090-0002 https://api.regulations.gov/v4/comments/CMS-2019-0090-0004 https://api.regulations.gov/v4/comments/CMS-2019-0090-0029 https://api.regulations.gov/v4/comments/CMS-2019-0090-0041 https://api.regulations.gov/v4/comments/CMS-2019-0090-0008
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On behalf of McKesson, I am pleased to submit comments on the proposed rule Medicare Program: Secure Electronic Prior Authorization for Medicare Part D (CMS-4189-P). Prior authorizations (PAs) were implemented as cost saving measure, to ensure that expensive medications were truly needed and that no less costly alternative was an option. Currently, prescribers and their staff spend an inordinate amount of time on PAs, sometimes nearly two workdays cumulatively (Robeznieks, 2018), putting the cost saving benefit into question. As electronic prescribing and electronic health records become the rule rather than the exception, it makes sense to tie the acts of prescribing and authorizing together. It is difficult to justify the upfront costs without looking at the bigger picture, because the entities subject to the upfront costs of converting to an electronic PA platform may not be the same entities benefiting from the cost saving. As both a healthcare consumer and a registered nurse, I can see clear benefit to this proposed change. From the provider standpoint, I have personally seen the snowball effect that the hassle associated with PA leads to. Patients can be deterred by the PA process, causing decreased medication compliance which ultimately causes larger health problems and increased cost. Research by CoverMyMeds, a company that produces electronic PA software, discovered that nearly 30 percent of these prescriptions are abandoned by patients(Beaton, 2018). As a person prescribed a medication that required a PA, it was frustrating to learn that often the prescriber was unaware of the PA requirement, since they can vary with insurance providers or the indication for the prescription. Having built-in alerts that inform the provider of the requirement, while prompting for the PA in real time simply makes good sense. Beaton, T. (2018). 96% of payers are committed to electronic prior authorization. Health Payer Intelligence. Retrieved from https://healthpayerintelligence.com/news/96-of-payers-are-committed-to-electronic-prior-authorization.Robeznieks, A. (2018). Cut prior authorization hassles through automation, EHR integration. American Medical Association. Retrieved from https://www.ama-assn.org/practice-management/sustainability/cut-prior-authorization-hassles-through-automation-ehr THIS PROPOSED RULE IS YET ANOTHER DEMAND ON  NONREIMBURSED PHYSICIAN TIME.  IF PASSED, IT MUST INCLUDE A FEE SCHEDULE, SUCH AS A  $25 FLAT REIMBURSEMENT PER GENERATED PAR. On behalf of the 32 member companies of the Electronic Health Record (EHR) Association, we are pleased to offer our comments to the Centers for Medicare  Medicaid Services (CMS) on the proposed rule for the Medicare Program; Secure Electronic Prior Authorization for Medicare Part D (CMS-4189-P.). We appreciate CMS objective to align the standards for e-prescribing with those used for prior authorization through Medicare Part D.   Dear Administrator Verma:On behalf of Dr. Saul Levin, M.D., M.P.H., the CEO and Medical Director of The American Psychiatric Association, please find our letter for CMS Proposed Rule: Medicare Program: Secure Electronic Prior Authorization for Medicare Part D CMS-4189-P. If you have any questions, please do not hesitate to contact me.Sincerely,Nathan A. Tatro, M.A.Associate Director of Digital HealthAmerican Psychiatric Association Amazing Charts LLC, a leading provider of Electronic Health Records and Practice Management solution for small independent practices, is supportive of the Secretary and the Administrations efforts to comply with the provisions of HR 6 SUPPORT for Patients and Communities Act (Act). Additionally, Amazing Charts is supportive of the NCPDP SCRIPT standard which was called out in the proposed rulemaking for Medicare Part D ePA; however, HR 6 permits the Secretary to call out the use of standard(s) vs. one standard; therefore we strongly encourage the Secretary to permit the use of other, existing standards and technology such as HL7, APIs and applications for electronic prior authorization when finalizing this rule-making.  Because other standard technology is currently available and implemented, should SCRIPT be the only standard permitted in final CMS rulemaking, we would see forward innovation in the industry hampered.  Additionally, the exclusive naming of the NCPDP SCRIPT standard runs contrary to the efforts of ONC in their Information Blocking Rule and the CMS Interoperability rule.  The naming of multiple standards in rulemaking would be conducive to the needs of the industry and would also support the language found in Section 6062 of the Act. Sincerely,Chris ConradProduct Manager, Amazing Charts LLC