CMS updates prior authorization transparency guidance in response to AMA recommendations
The Centers for Medicare & Medicaid Services (CMS) recently updated its guidance on federal prior authorization (PA) transparency requirements, incorporating several recommendations the AMA made following its review of how 15 Medicare Advantage contracts implemented the reporting provisions of the 2024 Interoperability and Prior Authorization final rule (CMS-0057-F).
The review revealed a consistent pattern: Many payers appeared to comply with the rule while presenting disclosures in places and formats that made them difficult or impossible to find or use. Payers posted hundreds of pages of billing codes without plain-language descriptions, buried required disclosures behind physician or member portals and deep within plan websites, reported mathematically impossible statistics and turnaround times without units, and omitted entire categories of care from public reporting.
The AMA documented these concerns and recommended corrective action in a May 2026 letter to CMS and reiterated several of those recommendations in its June 2026 comments on CMS-0062-P, which would extend PA transparency reporting requirements to prescription drugs.
The updated guidance addresses several of these problems by:
- Defining what it means for prior authorization information to be publicly accessible. CMS makes clear that disclosures are not publicly accessible if they are available only through password-protected portals or cannot be reached through ordinary navigation from a payer’s public-facing website.
- Clarifying that prior authorization disclosures must be understandable. CMS explicitly says lists of procedure codes without plain-language descriptions do not satisfy the requirement and recommends a single, comprehensive list organized by uniform service categories, with CPT codes, plain-language descriptions, and a machine-readable format.
- Standardizing how payers calculate reported outcomes. CMS now specifies the expected numerator and denominator for each metric, preventing payers from omitting entire categories of care from prior authorization reporting.
- Improving the accuracy and reliability of reported data. CMS clarifies that every turnaround-time metric must include a unit of time and requires median turnaround times of less than one day to be reported in hours rather than rounded to “0 days.” The agency also recommends that payers explain any data quality issue in their reporting by identifying the affected metric(s) and describing the limitation or quality concern.
As CMS moves to expand PA reporting requirements to prescription drugs, the AMA will continue working with the agency to ensure its transparency policies deliver on their promise of helping patients make informed decisions about their care, physicians navigate PA requirements, and regulators hold payers accountable for delays and denials—ultimately improving timely access to care for patients and reducing unnecessary burdens on physicians.
Legislation introduced to protect seniors from chatbots
The AMA recently supported legislation from Senators Mark Kelly (D-AZ) and Jim Justice (R-WV). The Senior Chatbot Protection Act establishes practical transparency, privacy and consumer protections for AI chatbots used by older Americans and helps to ensure people know when they are interacting with AI. The legislation was featured in a recent Senate Aging Committee hearing entitled "The AI Deception Machine: Deepfakes, Chatbots, and the New Frontier of Senior Fraud." The AMA was thanked during the hearing for our engagement and support of legislation to protect seniors from AI fraud.
An AMA quote of support for the legislation was included in the press release and communications on the legislation. “AI chatbots can help older adults access information and support, but they must be transparent, trustworthy, and designed to protect patients. The Senior Chatbot Protection Act establishes commonsense safeguards, including clear disclosure when users are interacting with AI, prohibiting false claims of professional credentials, protecting privacy, and directing people in crisis to appropriate emergency resources. The AMA applauds Sens. Kelly and Justice for their bipartisan leadership on legislation that would ensure AI serves as a tool to support physicians and patients — not a substitute for clinical expertise and human judgment," said AMA President Willie Underwood III, MD, MSc, MPH. The AMA looks forward to working with the bill sponsors and Congress to see commonsense protections for AI and chatbots across the finish line and signed into law.
