Dear Chair Hall, Chair Fields, 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 process. PAs can delay access to critical CF therapies, increasing the risk of serious health complications for patients. The Cystic Fibrosis Foundation supports efforts to minimize the administrative burden PAs impose on patients and their providers, enhance efficiency of the process, promote transparency of PA requirements, and ensure PA determinations are rooted in evidence.
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 20. 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 a 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’s 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 12 months. Eliminating unnecessary repeat authorizations will help promote immediate and consistent access to life-saving therapies for people with CF, and significantly reduce the administrative burden for CF care teams.
Response Times and Continuity of Care
SB 133 requires health plans to respond to all prior authorization requests within 72 hours for standard requests or 24 hours for expedited requests, 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.
Transparency for Prior Authorization Requirements
The Cystic Fibrosis Foundation applauds the provisions of SB 133 that increase transparency in the PA process, specifically the intent to require insurers to maintain a complete list of services that require PA, publicly share data on approvals and denials, and mandate that PA requirements and criteria — and changes to these policies — are easily accessible and clearly articulated. People with CF take many medications every day, many of which require prior authorizations. Each additional prior authorization can further exacerbate the administrative burden on both people with CF and their care teams as they navigate the criteria required to obtain these medications. Increasing the availability of information on prior authorization requirements and processes at the point-of-care will help reduce the administrative burden of these policies and streamline the process for care teams.
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 PA denials be made by a medical doctor who has expertise in the specialty area or is of an equivalent specialty as the health care provider submitting the PA request.
Conclusion
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.