AAPS Comments on Electronic Prior Authorization Standards

The Association of American Physicians and Surgeons (“AAPS”) hereby comments on the Request for Information: Electronic Prior Authorization Standards, Implementation Specifications, and Certification Criteria, as published in the Federal Register on January 24, 2022.

By way of background, AAPS is a non-profit membership organization of physicians and surgeons who are mostly in small, independent practices. Founded in 1943, AAPS defends and promotes the practice of private, ethical medicine. AAPS has members or supporters in virtually every specialty and State, and AAPS speaks out frequently on issues concerning patients and medical practice.

We feel that there is already too much governmental involvement in insurance and payment for medical services, and we oppose adoption or imposition of new electronic standards in connection with the practice of medicine, including the activity of obtaining prior authorizations. Insurance companies and other third-party payers already impose too much red tape, and government involvement in these issues tends to increase the regulatory burden even when the intention may be otherwise. We urge the government to rescind many of its regulations in this field, rather than adopt new regulations relating to payment for medical care.

AAPS particularly opposes any expansion in requirements to transmit anything electronically. Many physicians cannot afford to acquire and continually update the technology, or to hire staff to comply with the rules. There is also an increasing threat of data breaches, as well as data loss in the event of interruptions in service. We note that the President is warning about cyberwarfare.

Last year was plagued by disastrous breaches of privacy in electronic medical records. There were 686 reported medical care data breaches, and 44,993,618 such records were stolen or exposed. Reportedly nearly three-fourths of last year’s data breaches were due to hacking or other information technology problems. See HIPAA Journal (Dec 30, 2021).

At AAPS we have heard multiple times about electronic health record (EHR) systems being hijacked or down for days. These problems do not occur with such severity when records are on paper or handled by phone.

Thank you for your consideration of these comments.

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