NHeLP Comments on the HHS Prior Authorization Proposed Rule (2023)

Executive Summary

In these comments on the Prior Authorization Proposed Rule, NHeLP urges HHS to go further to curb the abuse of prior authorization as a cost savings strategy that endangers patients’ health. NHeLP supports efforts to streamline prior authorization processing and bring greater transparency to denial rates and the clinical criteria used by insurers when making medical necessity determinations. NHeLP’s comments also underscore the importance of Medicaid due process protections so enrollees can challenge unlawful denials of care.

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