Navigating New Prior Authorization Challenges Amidst CMS Reforms

The past year brought a wave of CMS policy changes reshaping prior authorization (PA) rules. For field reimbursement managers and market access teams, these reforms present both challenges and opportunities. The Jan 2024 Interoperability and Prior Authorization final rule (CMS-0057-F) and the 2024 Medicare Advantage/Part D rule (CMS-4201-F) impose strict PA deadlines, mandate transparency, and require new health IT capabilities. This guide highlights key changes, operational impacts, and strategies to streamline PA workflows, shorten time-to-treatment, and maintain compliance under the new rules.

Key Provisions of the CMS PA Reforms

• Shorter Decision Timelines: Starting Jan 2026, payers (Medicare Advantage, Medicaid/CHIP, and ACA marketplace plans) must issue PA determinations within 72 hours for expedited requests and 7 calendar days for standard requests【1】. This is a quicker timeframe for standard requests, which was previously 14 days. Plans that currently take longer will need to accelerate their review processes.
• Transparent Denials: Every PA denial must include a specific reason, communicated to providers (via portal, fax, etc.). This “reason-for-denial” requirement enhances visibility into coverage decisions and helps providers prepare accurate resubmissions or appeals【1】【6】.
• Public Reporting: Plans must annually post aggregate PA metrics (such as approval and denial rates) on their websites by March 2026. This improves accountability, enabling benchmarking and external oversight.
• Interoperability APIs: By Jan 1, 2027, payers must implement four HL7 FHIR-based APIs (Patient Access, Provider Access, Payer-to-Payer, and a Prior Authorization API)【1】. These APIs allow secure electronic queries of PA requirements, status tracking, and patient health data, streamlining information exchange between providers and payers.
• Electronic PA Measures: CMS has added an “Electronic Prior Authorization” measure in the Medicare quality programs, encouraging clinicians and hospitals to attest having used a certified EHR for at least one PA transaction. Adoption of ePA tools and FHIR integration will be supported by this measure.

From the 2024 Medicare Advantage/Part D Final Rule (CMS-4201-F) which complements the interoperability rule – key PA-related changes include:

• Coverage Criteria Alignment: MA plans must use Medicare’s national and local coverage decisions (NCD/LCD) and internal criteria must be evidence-based and publicly disclosed【2】. This prevents MA plans from imposing coverage rules that diverge from Traditional Medicare.
• Continuity of Care: When a patient switches MA plans during an ongoing course of treatment, the new plan must honor existing PA approvals for at least 90 days【2】. This transition safeguard avoids care interruptions.
• Utilization Management Committees: All MA plans must establish annual UM (Utilization Management) committees to review PA policies for consistency with Medicare coverage criteria【2】. CMS has proposed that by 2025, these committees include a health equity expert and conduct an equity assessment of PA policies【4】.
• Health Equity Focus: CMS is intensifying its equity requirements (e.g. a new Star Ratings Health Equity Index). Plans must expand culturally competent services, address digital literacy, and ensure equity in quality programs【2】. In its 2025 proposed rule, CMS even required MA plans to appoint an equity expert on PA oversight committees and annually assess PA policy impacts on underserved groups【4】.

These regulatory mandates dovetail with voluntary industry initiatives. In mid-2025, major insurers agreed to standardize PA processes by Jan 2026: reducing unnecessary PA requirements, implementing common ePA data standards (FHIR), honoring 90-day treatment transitions, and enhancing PA communication and appeals support【5】. Together, these reforms and commitments usher in faster, more transparent PA processes.

Operational Impact: Workflows and Compliance

• Payer Implications: Health plans must overhaul PA operations and IT. Utilization management teams will need new triage protocols, standardized criteria checklists, and maybe dedicated rapid-review staff to meet the 72h/7d clocks. IT departments must build or integrate the required FHIR APIs and connect them to provider systems. Payers should log every PA request, decision date, and denial reason to document compliance. Dashboards and reporting tools will be essential to track turnaround times and aggregate metrics (as CMS will require public reporting)【1】. Plans will also need processes to honor existing authorizations through patient plan changes (the 90-day rule for MA) and to maintain robust UM committee reviews.
• Provider Implications: Clinics and practices must tighten PA workflows to keep pace. This includes adopting electronic portals or EHR-based PA tools wherever possible if not already done so. Staff should be trained to collect full clinical documentation (e.g. imaging, labs, history) up front to prevent back-and-forth delays. Time-sensitive cases should be flagged immediately so the team can obtain required information and submit as an “expedited” request, meeting the 72-hour timeline. Setting up an internal tracker or dashboard can ensure PA requests are followed through and decision deadlines are met. Providers should also prepare to receive electronic denial notices with reasons, allowing faster appeal or alternative solutions. Aligning pharmacy, nursing, and finance teams around PA status will improve coordination.
• Health Equity & Access: The equity mandates mean payers and providers must consider disparities in PA processes. Plans may need to involve diverse stakeholders on UM committees and communicate PA decisions in clear, patient-friendly language and multiple languages. Health systems should deploy patient navigators or digital literacy programs to help vulnerable patients use any new web portals or mobile apps. Tracking PA outcomes by patient demographics (if available) can identify gaps. These steps will ensure compliance with CMS’s equity requirements【2】【4】 and help underserved patients navigate PA hurdles.

Regular compliance checks are essential. Both sides should audit workflows against the new rules: confirm that urgent requests are flagged, responses are logged, and reports are published. Since CMS can audit MA plans and providers for compliance, keeping meticulous records (time stamps on all PA actions, copies of denial notices, etc.) is critical. Building these compliance “guardrails” now will avoid future regulatory or audit issues.

What's Next?

• Embrace Electronic PA: Invest in certified ePA platforms and train staff on them. ePA systems can auto-populate authorization requests and handle form submissions directly to payers, vastly reducing manual steps and errors. FRMs should collaborate with IT and clinical teams to pilot CMS’s new Prior Authorization API as it becomes available, ensuring EHR systems feed PA data seamlessly. Over time, electronic workflows can dramatically cut the time-to-therapy by avoiding mail or fax delays.
• Negotiate Clear Contract Terms: Use these rules as leverage in payer negotiations. Request contracts or provider agreements that explicitly incorporate new PA standards: e.g. guaranteed decision timeframes (no more than 7 days), acceptance of electronic submissions, and continuation of approved treatments through plan changes. Insist that payers commit to advance notice of any PA criteria changes. The AMA’s contracting guide advises providers to clarify how payers define “medical necessity” and who reviews PAs【3】. FRMs can suggest language that binds plans to CMS-aligned PA policies (e.g. adherence to LCDs) and to timely appeals processes. If payers are unwilling to contractually guarantee 72h/7d, having the public CMS rule provides strong support for demanding it.
• Optimize Internal Workflow: Establish a cross-functional PA team (including clinical coordinators, pharmacists, financial counselors, etc.) to handle complex authorizations. Develop standardized forms or checklists for high-volume therapies so each request includes all insurer-required documentation. Automate reminder systems (calendars, EHR alerts) so team members act before the 7-day deadline. Track internal metrics: e.g. percent of PAs approved on first submission versus needing appeal. Reviewing these data weekly can identify bottlenecks or common documentation gaps. When novel therapies launch, coordinate early with providers to plan the PA strategy (e.g. pre-submission of clinical evidence to payers).
• Use Data and Focus on Patients: Leverage PA performance data in strategy. For example, if historical data show that most PA appeals for a certain drug are ultimately approved【6】, use that insight to negotiate a coverage agreement or remove the PA requirement entirely. Conversely, identify therapies with high upfront approval to target them for automatic coverage. Always keep the patient in focus: begin the PA process at diagnosis or prescription time to shorten wait-to-treatment. For urgent clinical scenarios, push for “expedited” labeling and meet the 72h timeline. Educate patients proactively: timely help with forms and appeals counseling can prevent abandonment. Prior authorization should be viewed not just as a gatekeeper, but as a data source – tracking outcomes (time to therapy, adherence) post-PA can demonstrate the value of prompt approvals and support market access discussions.
• Integrate Equity into PA Processes: Finally, make equity a visible priority. Ensure PA support materials are culturally appropriate and available to non-English speakers. Involve social services or community health workers when insurance changes threaten treatment continuity. Monitor whether any demographic group faces longer wait-times or denial patterns (if data permit) and share that with quality and compliance leaders. FRMs should partner with organizational diversity and compliance teams to align PA protocols with broader equity goals. These efforts not only satisfy CMS’s social risk requirements but also build trust with patients and providers.

Conclusion

CMS’s recent PA reforms, tighter deadlines, mandated transparency, and new technology requirements, are reshaping the landscape of access and reimbursement. By proactively retooling workflows, adopting digital solutions, and leveraging data, payers and providers can not only comply with these mandates but also turn them into operational advantages. The goal is faster, more consistent access to necessary care.

As these reforms raise the bar for documentation accuracy, regulatory awareness, and payer alignment, the role of trained reimbursement professionals becomes increasingly critical. Structured learning programs, such as the Prior Authorization Certified Specialist (PACS) certification, can support consistency in best practices, appeals navigation, and compliance with evolving CMS standards. For field reimbursement managers (FRMs) and access teams, applying such knowledge in day-to-day operations can lead to shorter time-to-treatment, reduced administrative friction, and stronger reimbursement performance, all while advancing equity and compliance under the new rules.

References

1. Centers for Medicare & Medicaid Services. CMS Finalizes Rule to Expand Access to Health Information and Improve the Prior Authorization Process. CMS.gov. January 2024. https://www.cms.gov/newsroom/press-releases/cms-finalizes-rule-expand-access-health-information-and-improve-prior-authorization-process
2. Centers for Medicare & Medicaid Services. 2024 Medicare Advantage and Part D Final Rule (CMS-4201-F) Fact Sheet. CMS.gov. April 2023. https://www.cms.gov/newsroom/fact-sheets/2024-medicare-advantage-and-part-d-final-rule-cms-4201-f.
3. American Medical Association. Payor Contracting Toolkit (Payor Contracting 101). AMA. May 2022. https://www.ama-assn.org/system/files/payor-contracting-toolkit.pdf.
4. American Society of Retina Specialists. CMS Proposes MA Plans’ Prior Authorization Policies Are Subject to Equity Assessments. ASRS.org. April 2024. https://www.asrs.org/advocacy/updates/10352/cms-proposes-ma-plans-prior-authorization-policies-are-subject-to-equity-assessments.
5. American Health Insurance Plans (AHIP). Health Plans Take Action to Simplify Prior Authorization. Jun 23, 2025. https://www.ahip.org/news/press-releases/health-plans-take-action-to-simplify-prior-authorization.
6. Schwarz C. Final Rules on Medicare Advantage Prior Authorization Offer Improvements, but More Change is Needed, May 30, 2024. https://www.medicarerights.org/medicare-watch/2024/05/30/final-rules-on-medicare-advantage-prior-authorization-offer-improvements-but-more-change-is-needed