The EHR Association submits prior authorization comments to CMS
Health care

The EHR Affiliation submits prior authorization feedback to CMS

On March 13, the HIMSS EHR Affiliation submitted its feedback to the Facilities for Medicare and Medicaid Companies on the proposed rule to advertise interoperability and enhance prior authorization processes.


Of main concern, EHRA strongly beneficial that CMS open a second remark interval as soon as the Workplace of the Nationwide Coordinator for Well being IT publishes its rule on affected person engagement, info sharing, and public well being interoperability.

A second remark interval will enable all stakeholders to revise the feedback as obligatory and reduce the potential prices of complying with two units of prior approval necessities, in accordance with the letter.

As well as, the seller group mentioned it wish to “evaluate and touch upon any conflicting and insufficiently harmonized necessities, which, in flip, will trigger pointless burden and duplication of labor.”

Relating to CMS’s present proposed rule, EHRA was fast to level out that prior authorization workflows require a number of payers, managed by CMS, and suppliers regulated by ONC to assist two ends of the workflow.

“If any of the specs for every social gathering battle, this two-way trade between a number of well being IT applied sciences on all sides won’t achieve success,” EHRA mentioned.

The seller group additionally famous that prior authorization requests ought to be shared with income cycle/affected person accounting techniques that require the authorization report for full claims, as the method could also be initiated in a number of well being IT techniques.

The requirement to publish API endpoints must also be clarified, whereas out-of-network suppliers ought to be included within the proposed supplier entry API necessities “following the identical course of necessities for consent and affected person efficiency lists,” EHRA mentioned.

As well as, requirements and implementation guides want additional growth and don’t adequately tackle what is required to allow totally different configurations inside payer and supplier organizations, the seller group mentioned.

“We imagine that CMS steerage on using particular requirements based mostly on HL7 FHIR is essential

and implementation information editions are aligned with these revealed by ONC by way of its Certification Program, together with the Development of Requirements Issuance Course of,” EHRA mentioned.

ONC is anticipated to offer a more moderen set of variations for the following certification program replace, in accordance with the company, and it urged CMS to make sure that necessities and adoption timelines stay in sync with ONC.

In response to CMS’ extra requests for info as a part of the remark interval, EHRA proposed to standardize social danger questions and permit sufferers to decide out of some questions and share concepts about how finest to interact community-based organizations .

Sellers’ crew says some social danger and social want components, resembling housing standing, are malleable and ought to be verified as nonetheless correct throughout future visits. Info from CBOs which will have offered help will not be sometimes returned to suppliers, the seller group says.

CBOs are vital stakeholders, in accordance with EHRA, which suggests CMS contemplate their restricted sources and the truth that they “preserve a mix of paper and fundamental applied sciences resembling Excel spreadsheets.”

EHRA added {that a} profitable technique might embrace direct subsidies or funding, in addition to together with CBOs in bigger fashions of value-based care.

“CMS ought to work with Congress, the Well being Sources and Companies Administration, and state businesses to discover focused initiatives based mostly on the successes of the HITECH Act.”

On the state degree, variations in particular person state privateness legal guidelines might hinder nationwide interoperability, EHRA says, and means that CMS might work to cut back variation whereas embracing TEFCA to prioritize future adoption instances social use.

“Such an method would be sure that the nation builds on the present well being care know-how ecosystem, folding group care into the bigger well being care image with their companion suppliers, not as a separate or stand-alone entity,” the seller group mentioned.

In recommending that CMS give attention to standardizing the social determinants of well being questions, however not require each company to gather each query, EHRA argues that not all specialties want them.

As a substitute, CMS ought to search to develop a constant, structured set of social danger and social wants questions, “resembling a federally outlined format for SDOH-related questions or standardized questionnaires.”

When it comes to coverage for the gathering and sharing of SDOH information, sufferers shouldn’t be required to reply each query, says the EHRA, which is recommending an opt-out choice to replicate the reluctance of some sufferers to reply sure questions.

“For instance, a homeless affected person with kids could also be cautious of answering questions on housing stability for concern that such info will set off a name to Youngster Protecting Companies,” the seller group advised

Total, EHRA recommends that CMS contemplate the next method to social determinants information:

  • Simply begin.
  • Encourage a constant sample throughout actors.
  • Develop federally standardized social danger questions.
  • Begin with a small set of questions which may be usually helpful in all care settings.
  • Enable practices to not tackle all questions when not relevant.

CMS requested about present standards beneath the ONC Well being IT Certification Program to allow behavioral well being interoperability, and EHRA known as it a superb start line, however the business wants extra clarification on consent workflows and dealing with of delicate information.

The seller group recommends that CMS “work with the well being IT business to handle labeling of delicate information or enable for elevated demarcation of opt-out/consent workflows.”

Relating to Medicare billing for service information trade, EHRA recommends that CMS work with Da Vinci and X12 to allow a constant method by clarifying the way to align requests for preliminary and extra prior authorization and declare info.

“This contains taking a look at Da Vincis CDex implementation information and exploring how comparable strategies could be utilized for attachments whereas utilizing X12 as the first transaction format,” EHRA mentioned.

For certification, EHRA recommends 18-24 months.

To advertise standardization and adoption of maternal well being information, “USCDI shouldn’t be used as a monolithic software, requiring all well being IT in search of certification to assist all USCDI.”

To advance TEFCA, EHRA mentioned CMS shouldn’t require suppliers who’re already actively engaged in information sharing by way of present networks to movement information by way of a Licensed Well being Info Community “except there’s a clear profit in value and completeness of the info”.

Requiring suppliers “to take part in two largely equal units of networks could be equally unhelpful, creating value and burden with out including worth”, EHRA mentioned.


Others assist prior authorization modifications, but additionally need CMS to align with ONC.

The Medical Group Administration Affiliation and the Digital Information Interchange Job Power need the CMS provisions carried out earlier than the present proposed date of Jan. 1, 2026, they mentioned.

Whereas each MGMA and WEDI agree that payers want a deadline to make prior authorization selections, however differ on that timeline, WEDI would additionally like CMS to determine alternatives to incentivize industrial payers to assist the necessities guidelines.

“We urge CMS to carefully monitor the business after the implementation date to find out whether or not these response occasions ought to be modified,” WEDI mentioned, and urged CMS to align with ONC’s certification program.


“The digital divide is clearly actual, as CMS is aware of, and it’ll seemingly take a HITECH-like program some form of monetary incentive construction associated to well being IT adoption to vary it throughout the board,” EHRA mentioned within the letter to CMS. .

Andrea Fox is editor-in-chief of Healthcare IT Information.
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Healthcare IT Information is a HIMSS Media publication.

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