Dear Chairman Marshall and Members of the Committee on Human Services,
On behalf of the nearly 150 people living with cystic fibrosis in Montana, we write to express our support for HB 398, which makes several important reforms to the prior authorization (PA) process. PAs can delay access to critical CF therapies and the Cystic Fibrosis Foundation supports efforts to minimize the administrative burden PAs impose on patients and their providers.
About Cystic Fibrosis
Cystic fibrosis is a progressive, genetic disease that affects the lungs, pancreas, and other organs. There are close to 40,000 children and adults living with cystic fibrosis in the United States, and CF can affect people of every racial and ethnic group. CF causes the body to produce thick, sticky mucus that clogs the lungs and digestive system, which can lead to life-threatening infections. CF care is grounded in evidence-based clinical guidelines and as a complex, multi-system disease without a cure, CF requires an intensive treatment regimen including multiple medications. For people with CF, it is not uncommon to take seven therapies every day, and as many as twenty. Many medications are taken year after year, and in most cases, for life. While advances in CF care are helping people live longer, healthier lives, we also know that the cost of care is a barrier for many people with the disease.
Prior Authorization Reform
Prior authorizations are one of the obstacles people with CF must navigate when accessing care. These requirements can delay the start or continuation of needed treatments, which can lead to adverse health outcomes. In a 2022 survey by the American Medical Association, 94 percent of physicians reported that prior authorizations led to delays in necessary care for their patients whose treatment required PA and 80 percent reported that PAs have led to patients abandoning their treatment at some point. Because CF is a progressive disease, patients who delay or forgo treatment — even for as little as a few days — face increased risk of lung exacerbations, costly hospitalizations, and potentially irreversible lung damage.
PAs can also cause significant administrative burden for CF providers and are often redundant for medications that people with CF must take indefinitely to maintain their health. In a CF Foundation survey of CF care teams, 58 percent of providers reported spending 20 percent or more of their time on PAs in 2016. This arduous process diverts valuable time and resources away from direct patient care.
The Foundation understands that payers adopt prior authorization policies to ensure patients only receive medically necessary care, and we recognize the challenge insurers face in managing medication utilization and cost. However, utilization management cannot come at the expense of delays in patient access to needed care. HB 398 provides an opportunity to make prior authorization processes more efficient, allowing for timely access to appropriate treatments. We appreciate Montana’ attention to this issue and support the following provisions in HB 398:
Medications for Chronic Diseases
Recognizing that people living with CF and other lifelong, chronic diseases take the same drugs for most of their lives, we appreciate that HB 398 exempts drugs and therapies used to treat chronic conditions from repeat authorizations and requires insurers to honor a prior authorization approval for 12 months. Eliminating unnecessary repeat authorizations will help promote immediate and consistent access to life-saving therapies for people with CF, and significantly reduce administrative burden for CF care teams.
Continuity of Care
HB 398 includes a continuity of care provision that protects patients from experiencing care delays when there are changes in coverage for a given treatment or when patients switch health plans. Gaps in therapy put people with CF at increased risk of costly hospitalizations and negative health outcomes. We support efforts to reduce delays in care and ensure people have timely access to their necessary medications.
The Cystic Fibrosis Foundation understands the challenge insurers face in managing medication utilization and the rising cost of health care. However, utilization management strategies that further burden patients and providers are unacceptable and cannot come at the expense of delays in patient access to needed care. HB 398 provides an opportunity to make prior authorization processes more transparent, efficient, and evidence-based, allowing for timely access to appropriate treatments.