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    September 13, 2022 

    The Honorable Chiquita Brooks-LaSure
    Centers for Medicare & Medicaid Services
    Department of Health and Human Services
    Attention: CMS-1751-P
    Mail Stop C4-26-05
    7500 Security Boulevard
    Baltimore, MD 21244-1850

    Subject: Medicare Program: 2023 Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs etc. (“OPPS Proposed Rule” or “Proposed Rule”)

    Dear Administrator Brooks-LaSure:

    The undersigned members of the Regulatory Relief Coalition (RRC), representing physicians throughout the country, are pleased to have the opportunity to comment on the OPPS Proposed Rule. The RRC is a group of national physician specialty organizations advocating for regulatory burden reduction in Medicare so physicians can spend more time treating patients. Our aim is to ensure that prior authorization (PA) is not a barrier to timely access to care for the patients we serve.

    The RRC is very disappointed that the calendar year (CY) 2023 OPPS Proposed Rule proposes to expand the list of hospital outpatient services subject to PA to include facet joint interventions. The RRC is extremely concerned about CMS’ incorporation of PA — traditionally a utilization control process used by managed care organizations — into the Medicare Fee-for-Service (FFS) Program. Over the past 10 years, health plans have increasingly used PA to reduce health care spending, substantially delaying medically necessary patient care and significantly increasing providers’ administrative costs. Obtaining PA from various Medicare Advantage (MA) and other health plans typically requires physicians or their staff to spend the equivalent of two or more days each week negotiating with insurance companies — time that would better be spent taking care of patients.


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