February 10, 2023: MGMA comments on prior authorization policies in the 2024 MA and Part D proposed rule

February 10, 2023 

The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
7500 Security Boulevard
Baltimore, MD 21244-1850

Re: [CMS–4201–P] Medicare Program; Contract Year 2024 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, Medicare Parts A, B, C, and D Overpayment Provisions of the Affordable Care Act and Programs of All-Inclusive Care for the Elderly; Health Information Technology Standards and Implementation Specifications

Dear Administrator Brooks-LaSure:

On behalf of our member medical group practices, the Medical Group Management Association (MGMA) thanks you for the inclusion of several critical and overdue reforms included in the Centers for Medicare & Medicaid Services’ (CMS’) Notice of Proposed Rule Making for Part C & Part D (“proposed rule”) that will reform certain aspects of prior authorization and have a positive impact on patient care.

With a membership of more than 60,000 medical practice administrators, executives, and leaders, MGMA represents more than 15,000 medical groups in which more than 350,000 physicians practice. These groups range from small private practices in rural areas to large regional and national health systems, and cover the full spectrum of physician specialties and organizational forms, making MGMA well-positioned to offer the following feedback.

 

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