LUGPA Policy Update: CMS Releases New Interoperability and Prior Authorization Final Rule (CMS-0057-F)
On January 17, 2024 the Centers for Medicare & Medicaid Services (CMS) announced the finalization of the CMS Interoperability and Prior Authorization Final Rule (CMS-0057-F). This rule is designed to advance the electronic exchange of health information and streamline prior authorization processes for medical items and services across diverse healthcare programs.
Key Provisions:
1) Scope of Impact:
- Applies to Medicare Advantage organizations, Medicaid and CHIP fee-for-service programs, Medicaid managed care plans, CHIP managed care entities, and Qualified Health Plans (QHPs) issuers on Federally-Facilitated Exchanges (FFEs).
- Collectively referred to as "impacted payers."
2) Prior Authorization Process Improvements:
- Establishes time limits for prior authorization decisions: 72 hours for urgent requests and seven calendar days for standard requests.
- Requires impacted payers to provide specific reasons for denial, promoting transparency.
3) HL7 FHIR Prior Authorization API:
- Mandates impacted payers to implement an HL7 FHIR Prior Authorization API (Application Programming Interface).
- It aims to automate the end-to-end prior authorization process, enhancing efficiency and collaboration.
4) Expanded API Requirements:
- Impacted payers must expand Patient Access API to include prior authorization information.
- Introduces a Provider Access API for providers to retrieve patients' claims, encounters, clinical, and prior authorization data.
5) Payer-to-Payer FHIR API:
- Allows the exchange of patient data between payers with patient consent, facilitating transitions or concurrent coverage.
6) MIPS and Promoting Interoperability:
- Adds an Electronic Prior Authorization measure for eligible clinicians under MIPS.
- Requires eligible hospitals and critical access hospitals to report their use of payers' Prior Authorization APIs.
Implementation Timeline:
- The primary implementation is set for 2026.
Additional Resources:
LUGPA members are encouraged to review the finalized CMS Interoperability and Prior Authorization Final Rule, recognizing its impact on prior authorization processes. This rule signifies a significant advancement in electronic health information exchange, fostering a smoother end-to-end prior authorization process. LUGPA will continue to follow the rule's progress and any additional guidance from CMS.
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