LeadingAge on October 8 2024 sent comments to the Centers for Medicare and Medicaid Services (CMS) on Service Level Data Collection for Initial Determinations and Appeals. Our comments support this effort to collect data from Medicare Advantage plans regarding their initial service determinations (including prior authorizations) and appeals. In addition, we highlight areas where additional items should be considered for inclusion as well as terms that require further clarification. Finally, we made a case for CMS to publish this data to assist consumers and the public in assessing the performance of MA plans on these processes.