Comments on R2024-03: Prior Authorization Modernization and SUD Treatment
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Comments from Kaiser Permanente to the Washington Office of the Insurance Commissioner regarding the prepublication draft rule R 2024-03 on prior authorization modernization and substance use disorder treatment; intended for the OIC rulemaking record and stakeholders affected by the rule.
Clarify timeframes for submission of missing information
Definition of non-electronic prior authorization request
Action Items for Providers and Carriers
Allow carriers to set a specific reasonable timeframe for missing information
Request that the rule explicitly allow carriers to establish a specific reasonable timeframe for submission of additional information per RCW 48.43.830(1)(c), rather than imposing the draft's fixed two-day and other time periods for all electronic and non-electronic requests.
- RCW 48.43.830(1)(c) permits a carrier to establish a specific reasonable time frame for submission of additional information.
- The prepublication draft appears to apply fixed two-day and other time periods to electronic and non-electronic requests rather than preserving carrier flexibility.
Clarify 'non-electronic prior authorization request' definition and its timing effects
Request clarification of the added definition for “non-electronic prior authorization request” so carriers know which methods are not considered electronic and when the electronic decision-making time periods apply.
- The letter thanks OIC for adding a definition of 'non-electronic prior authorization request' in WAC 284-43-2020 (10)(a)(ii) to clarify methods of communication not considered electronic.
- Clarification will help carriers understand when the various decision-making time periods apply and ensure consistency for requestors.
Defined Terms
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