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MGMA Washington Connection 03/16/2023

03/16/2023 2:52 PM | Rebekah Francis (Administrator)


On Monday, MGMA submitted comprehensive comments to the Center for Medicare & Medicaid Services (CMS) on its proposed rulemaking to reform prior authorization and interoperability within Medicare Advantage (MA) and several other payers. CMS proposed to make numerous changes such as implementing a process to facilitate prior authorizations, requiring affected payers to publicly publish aggregated prior authorization data, and more. MGMA offered the following key recommendations:

  • Finalize the inclusion of MA plans in the scope of the rule,
  • Finalize the proposal to require plans to provide specific reasons for prior authorization denials,
  • Shorten the proposed timeframes to 48 hours for standard prior authorizations and 24 hours for expedited prior authorizations,
  • Encourage the use of gold-carding programs in the MA program, and
  • Not link electronic prior authorization requirements to CMS’ Quality Payment Program (QPP).

CMS will now review comments submitted by the public before it finalizes the rule. Reforming the prior authorization process has long been one of MGMA’s top priorities. It is our hope that CMS will include MGMA's recommendations in its final rule and expeditiously publish it later this year.


Last Thursday, President Biden released his budget for fiscal year (FY) 2024. The Department of Health and Human Services (HHS) proposed $144.3 billion in discretionary and $1.7 trillion in mandatory budget authority. HHS’ section of the budget focused on addressing the following challenges the agency identified:

  • Addressing a growing behavioral health crisis,
  • Preparing for future health threats,
  • Strengthening insurance coverage and lowering health care costs,
  • Increasing funding to the Indian Health Service,
  • Improving the well-being of children, families, and seniors,
  • Growing the health workforce,
  • Improving departmental operations, and
  • Advancing research to improve health.

Agencies posted their budget justifications to Congress on Monday. CMS specifically identified three key initiatives regarding opioid and substance use disorders, health equity, and nursing homes in its 2024 congressional justification. As a reminder, the President’s budget is meant to be a messaging tool, especially in a divided Congress. It does not have the force of law and Congress will work through the appropriations process to fund the federal government in the coming months.


CMS has updated the 'Doctors and Clinicians' section of Medicare Care Compare and the Provider Data Catalog (PDC) with new Quality Payment Program (QPP) performance information for 2021. The Care Compare website is meant to allow for Medicare patients and caregivers to compare doctors, clinicians, accountable care organizations, and groups enrolled in Medicare.

CMS is required to report Merit-based Incentive Payment System (MIPS) eligible clinicians’ final scores, performance scores under each MIPS performance category, and the names of eligible clinicians in Advanced APMs. CMS is also required, to the extent feasible, to report the names and performance of Advanced APMs. The performance information is shown under percent performance scores, checkmarks, and measure-level star ratings.


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