February 13, 2023: MGMA and Regulatory Relief Coalition partners provide feedback on MA Part C and Part D proposed rule

February 13, 2023

Chiquita Brooks-LaSure
CMS Administrator
200 Independence Avenue, SW
Washington DC

Re: Medicare Program; Contract Year 2024 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, Medicare Parts A, B, C, and D Overpayment Provisions of the Affordable Care Act and Programs of All-Inclusive Care for the Elderly; Health Information Technology Standards and Implementation Specifications (“2024 MA Proposed Rule” or “Proposed Rule”)

Dear Administrator Chiquita Brooks-LaSure:

The undersigned members of the Regulatory Relief Coalition (RRC), representing thousands of physicians throughout the United States, write to thank you for the comprehensive prior authorization (PA) requirements in the contract year (CY) 2024 MA and Part D Proposed Rule. The RRC is a group of national physician specialty organizations advocating for regulatory burden reduction to ensure that utilization review policies are not a barrier to timely and equitable access to care for the patients we serve.

The RRC strongly supports the regulatory changes set forth in the Proposed Rule. We applaud CMS for its thorough and comprehensive proposed regulations, which, when finalized, will limit MA plans’ overuse and abuse of PA, reduce barriers to care and lessen provider burden. Finalizing the provisions in this Proposed Rule will help ensure that Medicare beneficiaries who enroll in MA Plans have the same access to Medicare-covered items and services as beneficiaries who opt for Medicare Fee-for-Service (FFS). Additionally, the issuance of this Proposed Rule in conjunction with the electronic PA (e-PA) proposed rule (which includes MA plans)1 will improve the efficiency of PA processes, reduce delays in care and alleviate the burden associated with PA.

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