LeadingAge, along with its Post Acute Care Coalition partners, on November 12, 2025 shared detailed recommendations with the Center for Medicare and Medicaid Services (CMS) for improving the Medicare Advantage (MA) prior authorization processes to better ensure beneficiaries timely access to post-acute care (PAC) services and to reduce the administrative burden on providers from Medicare Advantage (MA) prior authorization(PA) and concurrent review requests.

The solutions offered are in follow up to a July meeting between the PAC coalition and CMS that included a discussion of steps that could be taken to ensure PAC providers benefit from efforts to improve PAs.

The PAC coalition offered two detailed PA solutions to CMS:

• Require all MA plans to use a standard PA request form. The PAC coalition developed and included an example;
• Require all PAC PA requests to be treated as expedited with plan decisions required within 24 hours.

Of note, the solutions also recommend that concurrent review requests should require abbreviated data that reflects only the new information on the beneficiary since the prior request (e.g. progress, clinical notes, changes in condition) and that MA plans should not require concurrent reviews more than once per week.

Our detailed recommendations and sample standard request form sent to CMS can be viewed here.

Our goal with these solutions to is to ensure that as the Interoperability and Prior Authorization rule is implemented, with particular focus on the requirement that beginning in January 1, 2027 all MA plans must implement a PA Applicable Programming Interface (API) with a goal of speeding up decision making timelines and create an electronic bridge to communicate PA requests along with required documentation and plan decisions on those requests,  PAC providers and the older adults they serve will benefit.

We believe our proposed solutions align with the rule’s intent, insurer’s pledge to reduce and improve the PA processes, and the administration’s goals to reduce burden on providers and plans.

This paper reflects just one of our advocacy strategies for reducing the administrative burden of PAs on providers and ensuring beneficiaries have more timely access to needed skilled nursing facility and home health services.

It supplements comments we’ve already made about how to improve the MA program through standardization and simplification. We continue to support other regulatory changes and legislation to standardize, simplify and speed PA decisions.