Alliance Comments: Proposed Rule on Interoperability Standards and Prior Authorization for Drugs is Promising, but Needs Greater Oversight
Published June 11, 2026
The Alliance for Aging Research submitted comments of the Centers for Medicare & Medicaid Services (CMS) Proposed Rule on Interoperability Standards and Prior Authorization for Drugs.
The Alliance is encouraged that CMS is taking steps to mitigate the growing negative impact of prior authorization (PA) on patients, caregivers and their providers through timely electronic transmission of denials, appeals and clinical data, and presumably greater transparency and more detailed explanation for adverse decisions. However, the Alliance’s submitted comments note a grave omission that these new requirements will not apply to Part D plans (where PA practices have spiked considerably) and specific exclusion of Part D from certain improved data collection and reporting requirements.
The Alliance urges CMS to apply greater oversight across all Medicare plans and expand efforts to curb the growth and inequities of PA and step therapy. The Alliance calls for quick resolution of disputes (ideally 24 hours); portability of step therapy decisions across plans; and detailed, plain language, and plan specific disclosures of prior authorization/step therapy decisions, policies and metrics. The comments note the growth in step therapy for Part B drugs since it was first permitted in 2018 is especially concerning given that Medicare Advantage plans are statutorily required to reimburse all benefits covered under traditional Medicare.