Prior Authorization: How Did We Get Here and Where Are We Going?

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Dr. Chino discusses the past, present, and future of prior authorization in cancer care with Dr. Michael Anne Kyle, a health policy expert with a research focus on utilization management and patient burdens from prior auth.

TRANSCRIPT

Dr. Fumiko Chino: Hello and welcome to Put Into Practice, the podcast for the JCO Oncology Practice. I'm Dr. Fumiko Chino, an Assistant Professor in Radiation Oncology at MD Anderson Cancer Center with a research focus on access, affordability and equity.

On today's episode we'll be discussing prior authorization in cancer care. Prior auth has been a recent focus of healthcare policy and reform, given rising demands seen by both providers and patients. I'm excited to welcome an expert on prior authorization to the podcast today. Dr. Michael Anne Kyle is an Assistant Professor in the Department of Medical Ethics and Health Policy at the Perelman School of Medicine at UPenn. Her work focuses on defining and measuring patient administrative burden in cancer care delivery with a focus on prior authorization and how it impacts cancer care delivery, including patient wellbeing and outcomes. She holds a Ph.D. from the Harvard Business School, an MPH from the Harvard T.H. Chan School of Public Health, and a Master's in Nursing from the UPenn.

Our full disclosures are available in the transcript of this episode, and we've all already agreed to go by our first names for the podcast today.

Michael Anne, it's so great to speak with you today.

Dr. Michael Anne Kyle: It is so great to speak with you too, Fumiko. I'm really excited about this conversation and our shared interest in improving prior authorization.

Dr. Fumiko Chino: I love it that you've taken time out of your day to talk to me.

To start us off, can you tell us a little bit about yourself and your career? How did you transition from being a nurse into a health policy researcher? Did you always plan on a career in research or was there some specific event or transition that put you on this path?

Dr. Michael Anne Kyle: There was not. And so for anyone who's listening, who isn't sure what they want to do, I guess I have a good story to show that you actually don't need to know in advance. I started out as a critical care nurse and I still actually work as a critical care nurse. But as I think anyone who is a clinician who's listening to this knows, when you work in the healthcare system you just see so many things that could be different, that could be better. You notice the ways that the systems like really aren't set up for us to do our work or to take great care of our patients some of the time. And so that's really what sparked my interest in policy and in research. So I had really no background.

After working in a hospital, high acuity critical care, a lot of oncology, I spent several years working in community-based programs in New Jersey and this is before the Affordable Care Act. We were focused on access to medication, trying to get people more access to Medicaid, and did work around the initial rollout of the Affordable Care Act. And that experience where I spent a lot of time helping people enroll in social programs really gave me like some of the first insights into how much paperwork and how much time and how tedious it is to figure a lot of this out, even if you had someone helping you it’s still challenging. And that sort of stayed in the back of my mind as I went to grad school. And really what got me interested in like all the non-medical side of patient care is just like my friends and my family talking to me about it. And I think it's something we all just experience in our lives, but there just wasn't a ton of research. And so I've really been motivated to try to put some, like, numbers and evidence beside all these experiences that we know very deeply.

Dr. Fumiko Chino: So what I'm hearing is that you learned yourself by doing the work, how difficult the work was to actually obtain services for your patients, and so you decided you needed to go upstream to try to address some of the policies that were fundamentally broken, causing these horrible situations for your patients.

Dr. Michael Anne Kyle: So well said. Yes.

Dr. Fumiko Chino: Now, I heard that you just moved from Boston to Philly. How's that transition going?

Dr. Michael Anne Kyle: It's great, it's great. Many of the same familiar faces and also exciting to meet new people, learn new things, try new restaurants. So yeah, overall I feel very lucky.

Dr. Fumiko Chino: Well, with that background, we need to dive into our actual topic, which is prior authorization. It's unlikely that anyone listening to this podcast has not encountered prior authorization in their practice or due to interactions with insurance for themselves or for their family members. Can you give me a quick overview about prior authorization? What it is, what it is not, how did we get here?

Dr. Michael Anne Kyle: Oh, so every healthcare system needs some sort of coverage policy. What services are we going to cover and at what cost? And there's many ways to do this. There are countries that sort of set this up nationally. Here in the US, we do not do that. We do it prescription by prescription, and that's how we end up with prior authorization. So basically, prior authorization is a request you submit to get approval for coverage for a drug or a service that you want to give your patient. And so you may need to submit, and again, I'm sure everyone listening knows this well, but it can range for something very quick like, “Yes, this person has like the genetic target for this drug. Check, they can have it,” or it can be a more complex, protracted exchange. That is the sort of intellectual side of this. And I want to separate that from like the actual decision making from the other huge piece of prior authorization, which is how we operate it. And that is the bureaucracy and the fax machines and the time on hold, which has a separate bucket of problems. And so I just want to sort of carve out those two categories when I think about prior auth and what we need to do.

Dr. Fumiko Chino: One thing I always try to say is that even with prior authorization, even when it is working as functions, it is itself not a guarantee that a claim is even going to be approved. You can obtain prior authorization and then still face a denial for the actual claim, which is even more frustrating. And I think this kind of cumulative burden of suffering seems to me to be at an all-time peak. So can you give me a little bit of background about how the US healthcare system evolved to include prior authorization? Like why does this really even exist?

Dr. Michael Anne Kyle: Great question, and you'll get a different answer depending on who you ask. But overall, we need as a society to make a decision about the services that we are going to provide to one another. There's many different elements to that decision. One of the challenges in the United States is that we have little to no policy around cost. So when our healthcare can cost an unlimited amount, that makes it higher stakes and a trade-off is that there can be other restrictions on access. So we really don't have any constraints on cost in the U.S. other than administrative tools like prior authorization. And so that leads us to use it, I think, in ways it wasn't designed for, because there is a clinical use of prior authorization that's very appropriate, that we are doing complex things with patients that may or may not be a good fit, and we really want to figure out if this is the right match.

That is separate from healthcare is very expensive and unaffordable and we have no way to try and solve that problem except to try and put more restrictions in place, like making people go through a bunch of approvals and either discouraging them from going through that process or, you know, causing attrition through the process.

So I think one big element to how did we get here has to do with healthcare being very expensive and I think that dominates our minds. And I think there are other rationales for prior authorization that are very appropriate. But I think to your point, it's hard right now to see the times where it makes sense to go through this review process because so often you're experiencing prior authorization for treatments and medications where it just doesn't make any sense.

Dr. Fumiko Chino: One thing I've heard you speak before about is the Medicare Part D protected status that requires coverage for all or substantially all of drugs in the anti-cancer therapy treatment. Do you mind speaking a little bit about how that affects utilization management?

Dr. Michael Anne Kyle: Yes, great point. So one of like the most strictest restrictions you could put is exclusion - so you could just not cover a drug or a service. And we often don't think of that as a coverage restriction, but of course it is. But as you said, there are certain types of treatments and services where we have put in place policies to prevent exclusions because we thought these were important treatments and we didn't want them to be excluded from coverage. And in the Medicare program in Part D, which is the outpatient drug benefit, there are several categories of medications that are protected classes, and one of them is oncology drugs. So that means oncology drugs cannot be excluded from the Medicare Part D program unless there's a substitute. Like for example, if the drug goes generic, you could just cover the generic, but otherwise you have to cover everything. So that means that the only mechanism available to try and influence decision making and influence utilization is prior authorization. And that, I think, contributes to why we see such tremendously high rates of prior auth in oncology drugs in particular.

Dr. Fumiko Chino: So you're saying that a policy that was put in place in theory to help protect people with cancer may actually be placing disproportionate burden on them?

Dr. Michael Anne Kyle: Yes.

Dr. Fumiko Chino: Ironic.

Dr. Michael Anne Kyle: Yes.

Dr. Fumiko Chino: Virtually all patients and providers that I have talked to have felt like prior authorization has gotten worse in the last five years. Is this just a feeling or an emotion or does the data support that we're dealing with higher prior auth burdens more than ever before?

Dr. Michael Anne Kyle: Yes. So I think one reason prior authorization has come to the forefront of people's attention is because the prevalence is increasing. The reason for that seems largely to be driven by some larger changes in coverage, notably increase in managed care. So most of the Medicaid program is now in Medicaid managed care. In Medicare for older adults, Medicare Advantage is now a huge proportion of that program. So as managed care coverage becomes more prevalent, with that comes more utilization management tools. So then you face it more and more in your clinical practice and for your patients. So that's one major driver. And then the other thing is that as the cost of drugs goes up, so does the effort to contain costs.

Dr. Fumiko Chino: The downward pressure for cost management.

Dr. Michael Anne Kyle: Exactly.

Dr. Fumiko Chino: Now, you said managed care. And I just want to clarify for our audience, when you say manage Medicare or managed Medicaid, what do you mean?

Dr. Michael Anne Kyle: Thank you for reminding me to clarify. So in the sort of classic Medicaid or Medicare programs, or how insurance used to be when those programs first started in the 1960s, is, you know, you would like get your insurance card and you can just go around to anyone who takes that insurance. Managed care is just like a more active type of insurance where you'll have like a defined network - these are the doctors who are in your plan that you can go see, otherwise, you have to go out of network or these are the services that are covered, or these are the drugs that are covered. So managed care basically means the insurance company is taking a much more active role in the design of the benefit and so then that's why you'll see more utilization management.

Dr. Fumiko Chino: So instead of, for example, straight state Medicaid, which would be a state provided, federally funded plan, it's a private company who's actually providing those services through a contract through the state.

Dr. Michael Anne Kyle: Yeah.

Dr. Fumiko Chino: And similarly for Medicare Advantage plans, it's a private company who has decided to take the money from the federal government and then ends up providing your health care as someone who's over 65 who signed up for an MA plan.

Dr. Michael Anne Kyle: Yes. And there's two reasons that contracting ends up happening. One is that it's easier for budgeting purposes for the state, just kind of like issuing a contract. But the other thing is that states don't have the capacity to administer complex benefits. And so there aren't really like people to implement prior authorization or this type of complexity, like in the government itself. And so that's why we tend to see these kinds of practices more in insurance companies.

Dr. Fumiko Chino: Yeah, I was shocked. You know, one of the great wins of the, for example, Affordable Care Act was expansion of Medicaid, which seems great, you know, to provide health insurance to more people. But then along with that came the rise of the managed Medicaid programs, which is essentially, it sounds like states kind of got overwhelmed and could no longer manage their patients on Medicaid. Does that seem accurate?

Dr. Michael Anne Kyle: I think there's a couple of things. So one, this is the time period when I was still working in a lot of like, on the ground Medicaid public health work. So Medicaid expansion happens like still kind of in the aftermath of the Great Recession. So there had been tremendous layoffs in like, reductions in state capacity, while at the same time there was this huge expansion and like their scope of work. And so I think like a lot of the reason that managed care arose was that like they're just, you know, there had been these huge layoffs and there weren't people left in the Department of Health or in the Medicaid office. And so it was necessary to bring in external partners because the government had been understaffed.

Dr. Fumiko Chino: It's such a good point. I actually love this little bit of history you taught me because I'm always trying to tie the red thread to the red thread. Like this policy led to this either benefit or deficit. And I think, you know, stepping back one click further to say this was the environment in which these policies were enacted is so helpful when we put these things in context. It has like the benefit of talking with someone who's really a policy expert, that really helps me understand these things better.

Now, most of the data on prioritization has been really physician survey data. It shows that we hate it, it wastes our time, it increases staff allocation, it causes endless frustrations for us. Now, your work has mostly been focused on the burden on patients. Can you share what research has shown about this?

Dr. Michael Anne Kyle: I decided to focus on patients because there was just no evidence. And so there's not a ton, but there is some evidence about the experience of physicians, and everything you said is spot on. But my work finds that like you think that the pie is just what the physicians are dealing with or what the health system is dealing with, but actually like the pie is even bigger because there's this whole other chunk of work that patients are doing that we haven't really accounted for. Because of course you are spending your time after hours on hold, doing peer to peers, but at the same time, like letters are getting sent to the patient's house and they're trying to figure out what does this mean and they're also making phone calls, trying to understand what happened.

So I started this work with a national survey of adults 18 to 64 who are insured. This is just like people off the street, like not necessarily any particular health issues. And 1 in 4 people said they had delayed or foregone care in the past 12 months due to an administrative barrier. And one of those barriers was prior authorization that patients reported. And the structure of that question is the same as the way we ask questions about access barriers related to cost. And so the magnitude of barriers related to these administrative burdens is about the same as the barriers that people are reporting related to cost. And I think that's really important because we all have this sense that it's a hassle or a problem. I think it's only recently that we're understanding that it's not just frustrating, that it actually really does affect access. So that was like one step.

Then I have another piece of work building on that where I thought, okay, so patients are reporting that this is a problem and candidly that's sufficient because they're stressed and they don't feel well. But I looked at oral anti-cancer drugs and said, “Okay, like can we observe in data this phenomenon that patients are reporting that they're having issues with delayed and foregone care?” One of the challenges with claims data is you only see the claims that got billed. So we can't even see the people who got a prescription and never filled it. And I'm sure that you have many personal experiences of that with your patients and so do many of the people listening. But I'm not even able to see that in claims. So I just looked at people who were already taking a medication, already taking an oral anti-cancer medication. So we think, “Okay, they're consistently filling it so we know they're like on this regimen, and then their plan introduces a new prior auth policy on that drug and what happens to them?” And we find that people do experience delays in foregone care, that people with a new prior auth introduced on this drug they were taking have an average of a seven-day delay in their next fill after the prior auth, and that they have about seven times the odds of never filling that again. And this is for people, remember they're already taking this medication, which means they're connected to care, they have a doctor who's following them and there are policies saying in Medicare, and so this is in the Medicare population and there are Medicare policies which say, you know, you're supposed to just like roll people into coverage. If they already are on this medication and there's a prior auth, you're just supposed to continue and not impose a new prior auth on them. And that may be true, but in practice that policy isn't working because there's a delay of some kind.

We don't really know what's happening in that time. We just know there's a disruption. And whether it's because they have to do a prior auth anyway or they found out they didn't need a prior auth, the point is like there's an administrative barrier that's arising for people who are then not taking their imatinibs, not taking their erlotinibs, not taking their abiraterone. So like it's really concerning and that does not get us to health effects. One of the challenges in studying health effects is that the sample sizes get smaller and smaller and it's hard to attribute outcomes, especially for people with complex illnesses, to like one particular event or one particular cause. So that's something that sort of remains on my bucket list and hopefully on other researchers' bucket lists. But I think that you as a physician and the other people listening get a contextual sense that these are drugs that you really shouldn't be going off without, like a planned clinical reason.

Dr. Fumiko Chino: You know, the research that you just discussed was published last year in JCO, and I remember when I was talking to you about the study that you said something along the lines of you couldn't do an updated analysis now because this was a plan that didn't have a prior auth, that now needs a prior auth. And so you were looking at these transition points, whereas, by the end of the study period, basically every single plan had prior auths.

Dr. Michael Anne Kyle: Yes. So that study we looked at data from 2010 to 2020, I believe, or 2021. But most of these switches of like introducing new prior auths were happening in the first five years, usually before 2015, 2016. So I was trying to look at newer drugs like you said, but they're all coming onto the market with prior auth, and I can't study the new stuff because there's no variation to study. So thank you for mentioning that.

Dr. Fumiko Chino: So you can't document the harm of prior authorization because the best case scenario of no prior authorization doesn't exist.

Dr. Michael Anne Kyle: It's getting rarer and rarer for the oral cancer drugs, that's for sure.

Dr. Fumiko Chino: Now transitioning a little bit, there were many people, myself included, that were anticipating that prior authorization reform would make it into the lame duck session closing out 2024. Do you have any policy updates or insight into this?

Dr. Michael Anne Kyle: So I think the updated Improving Seniors’ Timely Access to Care Act, I've been following that for a couple of years and I think the latest iteration is quite good. It really focuses on these, like, administrative improvements that I think are really an urgent priority because there's no reason that we need to be having all these hassles with paperwork in 2025. I just want to mention this bill includes actual phrasing like a facsimile does not count as electronic documentation. And I was thrilled to see that.

So what I like about this bill, and I hope it will survive and endure, is that it speaks to a bunch of priorities that I think are important. One, everything needs to be automated or everything needs to be electronic. We’re still doing way too much fax, way too much paper. The bill doesn't mention whether the electronic requirement includes appeals, and it really should. If I was going to have one strong piece of feedback, it must, because I'm concerned that if we make the initial application process online, it'll just get denied and then appeals will be on paper and then we'll be back to square one. It also will really increase reporting and data access which will be helpful. One of the challenges in studying prior auth is that it's hard to get good data. Like I said, claims data, we only see things that were billed. We don't really have a great sense of payer policies. And this bill would require reporting from payers to say like what their prior authorization requirements are, denials, appeals, grievances and so on, which will be very helpful.

Although I want to highlight on this point, there's some new work on billing, which I don't think will come as a surprise to any of us that there are unfortunately inequities in the appeals process. And so this is work by Alex Hoagland and Michal Horny and colleagues and they looked at preventive services which are supposed to be covered under the Affordable Care Act. So you have some like objective sense of what the bill should look like. And they look at errors and then they look at appeals. And there are inequities by race, there are inequities by education and income in who is even appealing an erroneous bill and then how successful you are in appeal. And so while I think more transparency throughout this process is great, I remain concerned that like relying on patients and physicians to recognize and initiate appeals places disproportionate burden on our patients who can least afford it.

Dr. Fumiko Chino: I was personally very disappointed that the Improving Seniors’ Timely Access to Care Act, which is the world's longest House and Senate bill title, wasn't part of the end of year spending package. I was really hoping we could pass it through the finish line, especially because it has a zero-cost dollar from the CBO, which was a major point of resistance before. And I know this is something that both our ASCO and ASTRO, our large societies for oncologists, have really been trying to rally support around consistently and it really does seem to have bipartisan support.

So outside of federal legislation that did not make it into the spending package, how do we fix this? You know, I was rereading your New England Journal of Medicine 2023 Perspectives, highlighting some potential consequences and barriers to prior authorization reform. Can you discuss this as well as whatever specific federal, state, institutional policies or even really provider level advocacy that you feel like could get us out of this mess?

Dr. Michael Anne Kyle: Sure. I still have hope for the Timely Access to Care Act because it's been kicking around for a few years and it keeps getting worked on, improved. So hopefully 2025 will be our year. The perspective that you're talking about refers to a CMS rule that at the time was open for comment but has since been passed and is scheduled to sort of go into service in 2026, 2027. And that incorporates a lot of the same elements as the Timely Access to Care Bill. So for example, it requires that these processes be electronic. Again, the question of appeals is a little bit vague, but making them electronic, requiring the reason for denials to be provided, providing paperwork to the patient and to the physician about the status of the application, and if it's denied or has a problem, why. There's a whole like IT element of this where there's a patient portal piece so that patients would also be able to log in and track the process themselves. On the one hand, I think that's nice for people who want to, you know, follow along. On the other hand, you know, if you don't feel well with cancer, ideally this should be getting addressed without you having to log in and check up on it. You could be like resting, recovering, enjoying your family. But overall, I think there's an understanding that we have to move away from this very analog process that we have now. So that I guess is going to come online starting in about 12 months. And then there's a bunch of work going on at the state level. Some states are requiring electronic PA, which I think is terrific.

Throughout these bills, there's also some time deadlines on these decisions. So I think having a turnaround time, whether it's like 72 hours or seven days, whatever it is, I think it's good to put those into place. I worry about an unintended consequence will be that if they can't meet the deadline, they would just deny it and you would go to appeals. And again, coming back to my fixation on like, what does the appeals process look like, but I think overall it would be very helpful to have some like, better definition and better clarity.

One thing I haven't seen in these, but I hope that policymakers and advocates will become interested in is I would really like to see some more standardization of these forms across payers. Obviously, the dream would be like standardization and actually like the parameters. But even if we can't get there at least like the paperwork could look the same because there's a lot of duplicated effort in filling out the forms and submitting these. This is really unnecessary, like it should all just look the same. And we keep reinventing the wheel which slows everybody down. And I think there's a huge policy opportunity there to promote standardization that if we have to do this, like at least it could be less painful.

Dr. Fumiko Chino: Absolutely. And I always try to highlight when I think about state level legislation, things like Gold Card Acts to my knowledge have not included any cancer services as part of what you could be gold carded for. At least not, again, not that I'm aware of at the various states where they have passed Gold Card legislation, which is a promising way of facilitating approvals. But so far, cancer patients are still kind of left out of that. Have there been any institutional policies that you've noticed seem like they help with prior authorization?

Dr. Michael Anne Kyle: No. And I think a lot about my research, like who my audience is and its organizational leaders and policymakers. And I would really like to see clinical organizations advocate for more standardization and more process improvement. I understand the emphasis on like we don't like prior auth and we want less, but I think there's an easier win in asking for this system to work better. And I'd love to see some of our health care organizations put their weight behind that.

Dr. Fumiko Chino: I have to say, since transitioning institutions to MD Anderson, I've actually been very pleasantly surprised within our radiation oncology department how streamlined the process is. And I think it's because we had a motivated faculty member who went deep into the prior authorization process and why the plans were being denied, got all of the constraints that would trigger an approval and basically built them into our planning process. So it's been really streamlined, but it was a lot of investment upfront to kind of get it to the point where it is now.

Well, I think we are wrapping up our time together. Do you have any last thoughts about prior authorization or have what we already said has it been disappointing enough?

Dr. Michael Anne Kyle: Well, let me finish on a positive note. I think what's exciting about this is that we've spent many decades on trying to improve the cost challenges in healthcare. We have the Affordable Care Act. I don't think we've yet put the same effort into non-financial costs. And so I think there is a lot of hard, hard stuff ahead. But I think there's also a lot of these challenges I think exist because no one has looked at them yet. Like how much prior authorization is like a strategic decision? And I ask this to everyone, how much is it of it is a strategic decision versus how much is like the manual is lying in someone's cubicle and hasn't been updated in years and if only someone with decision making authority looked at it, they would be like, “Oh, yeah, you can take prior auth off it”? You know, like, I just think that there's a huge opportunity to do better here because we haven't paid it enough attention. So I think we should be hopeful and I want to do better for our patients. Like I want to feel prouder of the healthcare system that I'm a part of.

Dr. Fumiko Chino: 100%. No, I love that. And that's a great hopeful end, which is that with data maybe we can start to work our way out of this. And so that's maybe a siren call for researchers coming online to think about galvanizing yourself to provide data as to what we can do to improve.

Well, thank you so much for such a robust conversation today about such an important topic. So many thanks to both Dr. Kyle and to our listeners for your time today.

For listeners that are interested in advocacy, I would encourage you to visit the ASCO ACT Network where you can send pre-drafted letters to your lawmakers on important legislative issues impacting cancer providers and their patients, things like prior authorization.

You will find the links to the papers that we discussed in the transcript of this episode. If you value the insights that you hear from the JCO OP Put Into Practice podcast, please take a moment to rate, review and subscribe wherever you get your podcasts. I hope that you'll join us next month for our next episode. Until then, keep fighting the good fight for our patients.

The purpose of this podcast is to educate and to inform. This is not a substitute for professional medical care and is not intended for use in the diagnosis or treatment of individual conditions.

Guests on this podcast express their own opinions, experience and conclusions. Guest statements on the podcast do not express the opinions of ASCO. The mention of any product, service, organization, activity or therapy should not be construed as an ASCO endorsement.

Guest’s Disclosures:

Dr. Michael Anne Kyle No relationships to disclose.

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