HCA has submitted formal comments to the Massachusetts Division of Insurance (DOI) on the proposed amendments to 211 CMR 52.00, which govern prior authorization requirements across commercial health plans.

 

Our comments were informed by direct feedback from home health agencies across Massachusetts and reflect the real-world impact prior authorization requirements have on home-based care delivery.

 

HCA emphasized that prior authorization requirements remain highly inconsistent across payers, with variation in portals, documentation requirements, approval timelines, and reauthorization frequency. Many agencies report that these inconsistencies delay care initiation—particularly around weekends and holidays—and shift financial risk to providers when care must begin before authorization decisions are finalized.

Importantly, agencies noted that the core issue is not clinical oversight, but the lack of standardization, transparency, and timely decision-making across plans.

 

In its comments, HCA expressed strong support for several of the DOI’s proposed reforms, including eliminating prior authorization for post-acute care services provided on weekends or holidays, improving transparency around authorization requirements, and establishing continuity-of-care protections to prevent disruptions to active episodes of care.

 

HCA also highlighted the unique nature of home health services, which require in-home assessment before a complete plan of care can be developed. Based on this reality, HCA recommended allowing at least an initial, two-week, time-limited authorization period to support timely access to care while preserving appropriate oversight.

 

HCA further urged the DOI to explicitly define “post-acute providers” to ensure that home health agencies and hospice providers are clearly included in the final regulation.

 

Thank you to the agencies that participated in HCA’s rapid prior authorization survey. Your input directly shaped our advocacy and continues to inform our engagement with state policymakers.