On June 15, PCMA submitted comments to CMS on its proposed rule to advance interoperability and electronic prior authorization (ePA) for prescription drugs. The proposal reflects years of work by policymakers, health plans, pharmacy benefit managers (PBMs), providers, and technology developers to modernize how prescription drug information moves across the health care system.

Better interoperability can create a more seamless experience for patients and providers by helping reduce administrative burden and expediting access to needed therapies. Electronic prior authorization, electronic prescribing, and real-time benefit tools all have the potential to improve prescribing decisions and reduce delays in care.

However, one theme emerged throughout our comments: technology alone is not enough.

Today, much of the discussion around prior authorization focuses on payer requirements and system capabilities. Yet many of the tools CMS is seeking to promote already exist. PBMs and health plans have spent years investing in electronic workflows and interoperability infrastructure. The next challenge is ensuring those tools are consistently adopted and integrated into provider workflows.

That is why our comments encourage CMS to look beyond technical mandates and focus on broader adoption across the health care ecosystem. The benefits of ePA and real-time benefit tools can only be fully realized when they are used at the point of care, where prescribing decisions are made. When providers have access to real-time coverage information and electronic authorization tools within their existing workflows, patients are more likely to receive timely access to appropriate medications and avoid unnecessary delays.

We also encouraged CMS to take a practical approach to implementation. The proposed rule would require significant coordination among PBMs, health plans, providers, pharmacies, electronic health record (EHR) vendors, and other technology partners. Given the scope of the changes, additional implementation time and alignment with other federal interoperability initiatives will be critical to ensuring a smooth transition and avoiding disruptions to patient care.

Finally, we highlighted the importance of maintaining flexibility as new standards evolve. Interoperability is not a one-time project; it is an ongoing process that requires collaboration, continuous improvement, and a willingness to adapt as technology advances. CMS’s proposal represents another important step forward, but success will ultimately depend on coordinated participation from all stakeholders.

As CMS reviews feedback and moves toward a final rule, PCMA looks forward to continuing to work with patients, regulators, providers, technology partners, and other stakeholders to advance solutions that improve patient access, reduce administrative burden, and support a more connected health care system.

Read the full letter HERE.