Dear Chairman Bjorkman and Members of the Committee on Labor and Commerce:
On behalf of the people living with cystic fibrosis in Alaska, we write to express our support for SB 133, 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, enhance efficiency of the process, and promote transparency of PA requirements.
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 2023 survey by the American Medical Association, 94% of physicians reported that prior authorizations led to delays in necessary care for their patients whose treatment required PA and nearly 80% 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% of providers reported spending 20% 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. SB 133 provides an opportunity to make prior authorization processes more efficient, allowing for timely access to appropriate treatments. We appreciate Alaska’ attention to this issue and support the following provisions in SB 133:
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 SB 133 exempts drugs and therapies used to treat chronic conditions from repeat authorizations and requires insurers to honor a prior authorization approval for at least twelve 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.
Response Times
SB 133 requires health plans to respond to all prior authorization requests within 72 hours for non-urgent services or 24 hours for urgent services, thereby ensuring timely access to treatments. 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.
Evidence-Based Review
One of the purposes of prior authorization is to verify the clinical appropriateness of a service, so it is crucial that insurers use evidence-based criteria when developing prior authorization requirements. CF treatments have very clear indications established by the Food and Drug Administration and it is essential that prior authorization criteria reflect the data and label approval. To that end, SB 133 requires insurers to review their prior authorization criteria annually and ensure that their criteria reflect current medical and scientific evidence. Additionally, the bill requires that insurers establish processes for providers to request clinical peer review of a prior authorization request. The peer reviewer must be a medical doctor who has expertise in the same specialty area as the provider submitting the PA request.
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. SB 133 provides an opportunity to make prior authorization processes more transparent, efficient, and evidence-based, allowing for timely access to appropriate treatments.