The public comment period just closed for the Centers for Medicare and Medicaid Services’ (CMS) proposed rule on “Advancing Interoperability and Improving Prior Authorization Processes.” And as of 11:59 PM March 13, the CMS had received close to 1,000 comments, including one from Myndshft. Below is a quick recap of our response. 

Want more details? Check out our Myndshft response to the CMS request for public comment in its entirety. 

Addressing prior authorization crucial for value-based care success

Rampant process inefficiencies slow progress toward value-based care. Today’s manual prior authorization process is time-intensive and costly, and that won’t change without real-time data sharing between providers and payers. That’s why Myndshft, along with numerous others, welcomes ongoing efforts by the CMS to address interoperability and prior authorization process challenges. Our comments reflect our unique insights into the technology side of automated prior authorization. 

HL7Ⓡ FHIRⓇ APIs a good start, but Da Vinci standards are needed.

FHIR APIs offer the robust security and flexibility needed to serve a multitude of different healthcare use cases while protecting sensitive healthcare data. However, healthcare providers will need to make significant investments to support myriad data formats. Using Da Vinci standards would create consistency that reduces the complexity and administrative burdens associated with prior authorization. Check out three ways the Da Vinci standards help providers, payers and health information technology vendors.

Current HIPAA standard 278 transaction falls short in today’s environment. 

The proposed rule maintains an existing standard for using the 278 transaction to transmit data. The 278 transaction, however, lacks the robustness needed to meet evolving needs. For consistency in requirements and to ensure future success with minimal disruption, Myndshft recommends removing the 278 transaction requirement in favor of using HL7 FHIR standards directly. 

The current drug exclusion should be lifted for medically-billed drugs.

Rather than exclude all drugs, as the proposed rule currently stands, Myndshft offers an alternative. We recommend that medically billed drugs (drugs with an HCPCS code) be included in the requirement. Only drugs billed to the PBM via NCPDP standards warrant exclusion. 

Interoperability remains a work in progress. The latest rule revises a previous rule based on past public comments. This shows that the CMS is committed to taking input from healthcare stakeholders. Let’s move the needle forward together. 

For more information about our automated prior authorization software, contact us.