MGMA Advocates for HHS OIG Study on the Impacts of Step Therapy Requirements (August 4, 2025)

August 4, 2025

RE: Request for HHS OIG Study on the Impacts of Step Therapy Requirements

Dear Inspector General Hodgkins,

The undersigned organizations, representing millions of Medicare beneficiaries with lifethreatening, complex, chronic conditions and the physicians who care for them, are reaching out to the Health and Human Services Office of the Inspector General (HHS OIG) to express our appreciation for the agency’s continuous focus on Medicare Advantage (MA) plans’ use of prior authorization. We also would like to share our concerns, similar to those which inspired the OIG’s reports on prior authorization, regarding MA plans continuing and expanding use of step therapy requirements for Part B drugs. For the reasons outlined below, we encourage HHS OIG to conduct a study and report on the impacts on Medicare beneficiary access to medically necessary care created by MA plans’ use of step therapy for Part B drugs.

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