In a letter to the Centers for Medicare & Medicaid Services (CMS) Administrator Seema Verma, MACPAC comments on a proposed rule that would streamline processes for prior authorization and create new requirements for Medicaid and CHIP fee-for-service programs and managed care plans and for qualified health plans on the federally facilitated exchanges.
While MACPAC is generally supportive of efforts to reduce payer and provider burden and improve patient access to health information, the Commission expressed concern that the period allowed for public comment—just 17 days spanning a period with three federal holidays—is insufficient given the complexity of the proposed rule and the new requirements it will impose on states and health plans.
The proposed rule also exempts Medicare Advantage (MA) plans from the new requirements, which CMS acknowledges would “create misalignments between Medicaid and Medicare that could affect dually eligible individuals enrolled in both a Medicaid managed care plan and an MA plan.” MACPAC is concerned that creating additional misalignments between the two programs would make it more difficult to integrate care for this high-cost, high-need population.
The notice of proposed rulemaking also includes a request for information on how to help behavioral health providers better leverage technology to exchange health data and improve care quality and coordination. During MACPAC’s December 2020 meeting, the Commission focused on the relatively low use of certified electronic health record technology that supports sharing of standardized health records with physical health providers. This is an area where MACPAC expects to continue working in the months ahead.
