September 6, 2022

On August 31, APMA submitted comments to CMS on its Request for Information seeking input from the public regarding various aspects of the Medicare Advantage (MA) program. According to CMS, the agency uses this information to help inform future rulemaking or other policy development. Read the letter in its entirety at www.apma.org/comments.

In its response, APMA focused on expanding access to coverage and care and reducing burdens on physicians and beneficiaries and addressed the following issues:

• Prior Authorization. While APMA agrees with the need to increase alignment in the prior authorization process among MA and Part D plans to streamline operations, increase transparency, and reduce provider burden, APMA is concerned that CMS is not placing enough emphasis on the underlying burden prior authorization creates. Specifically, prior authorization imposes significant paperwork requirements and reduces clinicians’ time and ability to focus on delivering high-quality care.
• Star Ratings. APMA encourages CMS to develop and implement a Star Ratings measure specifically related to plan coverage and payment decisions, claims processing issues, and other common administrative processes. APMA believes such an effort will help to ensure patient access to care and to limit plan implementation of unnecessary and excessively burdensome requirements. 
• Record Requests. APMA and related societies from the provider community shared our concerns and recommendations with CMS to reduce the administrative burdens of onerous record requests on physician offices. APMA is disappointed that CMS has yet to take action on our recommendations through rulemaking or other regulatory mechanisms, so we are sharing our comments with CMS again and urging the agency to reduce the administrative burden of medical record requests from MAOs.

You can review this letter and see other comments at www.apma.org/comments, and look for future updates on APMA Weekly Focus and related outlets.  For more information on Medicare Advantage Plans, visit www.apma.org/medicareadvantage.

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