CMS Final Interoperability and Prior Authorization Rule: Impacted Parties, API Implementation, Reporting Requirements

Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Health
- event Date
Tuesday, April 2, 2024
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
-
This 90-minute webinar is eligible in most states for 1.5 CLE credits.
This CLE webinar will guide counsel on the final Centers for Medicare & Medicaid Services (CMS) interoperability and prior authorization rule. The panel will discuss impacted parties, required updates to and implementation of application program interfaces (APIs), and new requirements to the prior authorization process. The panel will also address important timelines and provide best practices for compliance.
Faculty

Ms. Lucas has broad experience in healthcare compliance and regulatory issues. She frequently advises health plans across the country on compliance with the Consolidated Appropriations Act of 2021 (CAA), the Affordable Care Act (ACA), and government program rules. Ms. Lucas has experience in specific compliance issues involving Medicare Advantage Plans, Medicaid Managed Care Organizations, Marketplace products, and Employee Retirement Income Security Act (ERISA) plans and administrators. She has represented health plans in litigation and arbitration, including in matters relating to ERISA and government program compliance, contractual payment disputes with hospital systems and providers, and high volume claim disputes with out-of-network providers. She is also passionate about legal technology and develops innovative, cost-saving legal products using artificial intelligence, document automation, and knowledge management tools.

Ms. Leiter focuses on health information privacy, new data use cases, data policy and health regulatory issues. She advises academic medical centers, plans, providers and information technology companies on a wide range of compliance and policy issues for data not covered by the Health Insurance Portability and Accountability Act (HIPAA) and related state privacy laws. Before joining the firm, Ms. Leiter served as vice president and senior counsel to Executives for Health Innovation in Washington, D.C., where she helped develop a privacy framework to govern health data not covered by HIPAA.

Ms. Moundas is co-head of the firm's digital health initiative and actively participates in the data, privacy & cybersecurity group. She provides strategic, regulatory, compliance, and transactional advice to healthcare clients, including health systems, hospitals, academic medical centers, long-term care providers, pharmaceutical companies, digital health companies, and investors. As part of her practice, Ms. Moundas also counsels clients on privacy, security and breach matters, and focuses on emerging issues in the digital health space. Prior to joining the firm, she worked for over five years in the U.S. Department of Health and Human Services Office of Inspector General. Ms. Moundas’ work focused on the oversight of certain aspects of federal reimbursement policy, federal fraud and abuse and program integrity initiatives, the Medicare administrative appeals process, as well as national health information technology initiatives.
Description
The CMS recently released its final interoperability and prior authorization processes rule that will require certain payers to automate their prior authorization processes and implement APIs to improve the exchange of health information among payers, providers, and patients. Impacted payers include Medicare Advantage/Medicare Part D plans, state Medicaid and Children's Health Insurance Program (CHIP) fee-for-service programs (FFS), Medicaid managed care plans and CHIP managed care entities, and Qualified Health Plan issuers on the Federally Facilitated Exchanges (FFEs).
The new rule complements the Office of the National Coordinator for Health Information Technology's efforts to improve the access, exchange, and use of electronic health information and aims to reduce provider burden related to prior authorization processes and improve patient access to timely care.
Key provisions of the new rule include: (1) updating requirements for the previously established Patient Access API and establishing three new required APIs--Provider Access API, a Payer-to-Payer API, and a Prior Authorization API; (2) outlining new timeframes for prior authorization decisions; (3) requiring impacted payers to provide specific reasons for denials of prior authorization requests within the new timeframes; (4) creating new reporting requirements for impacted payers related to certain aggregated prior authorization metrics; (5) creating new electronic prior authorization measures for the Merit-Based Incentive Payment System and the Medicare Promoting Interoperability Program; and (6) providing certain extensions, exemptions, and exceptions to state Medicaid and CHIP FFS programs.
Listen as our expert panel guides practitioners through CMS' final interoperability and prior authorization rule and provides a compliance timeline. The panel will offer best practices for addressing the required changes and steps for complying with the new regulations.
Outline
- Introduction
- Updates to and implementation of APIs
- New requirements for prior authorization processes
- Compliance timeframe
- Notable exclusions
- Best practices for compliance
Benefits
The panel will review these and other key considerations:
- How will the new rule affect healthcare providers, payers, and patients?
- What are the new timelines of which counsel and their clients should be aware?
- Why should impacted parties begin preparing for compliance now?
- What exceptions/exemptions are offered in the new rule?
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