Executive Summary
In these comments to HHS, NHeLP continues to raise concerns with the use of prior authorization as a barrier to access necessary care for low-income and underscored individuals. While supporting the application of prior authorization standards previously adopted for other services to drugs, NHeLP comments also urge HHS to strengthen transparency around metrics and information on medical necessity criteria used by plans to deny coverage of prescription drugs. The comments also emphasize NHeLP’s position that the Medicaid notice and hearing provisions should be extended to individuals enrolled in other plans and programs.
