Employer Statement of Support Encouraging TPAs to Expand the Prior Authorization Pledge to Self-Insured Plans

The Centers for Medicare & Medicaid Services (CMS) and the Employee Benefits Security Administration (EBSA) at the Department of Labor are announcing a critical statement of support from major American employers on expansion of electronic prior authorization reform to the self-insured markets.

Background

Prior authorization delays harm patients and burden providers, regardless of the type of insurance plan a patient is enrolled in. Providers shouldn't need to determine the type of insurance plan a patient is enrolled in before choosing the pathway they use to submit a prior authorization request. A fragmented system creates confusion, delays care, and excludes many patients from benefitting from the prior authorization reforms that CMS and industry partners have undertaken over the past year. This is why CMS and EBSA are proud to announce that self-insured employers are joining the growing coalition of stakeholders committed to advancing electronic prior authorization and improving the prior authorization process more broadly.

Under the 2025 Prior Authorization Pledge, leading insurance companies committed to improving the prior authorization processes for their Medicare Advantage, Medicaid Managed Care, Health Insurance Marketplace®, and commercial plans. Self-insured employers, who cover millions of Americans through self-insured health plans, are now calling on their third-party administrators (TPAs) to offer these pledge provisions to their employees. By bringing self-insured employers into the fold, we're ensuring that the entire health care ecosystem moves together and that patients experience faster, less burdensome care decisions. These self-insured employers are encouraging their TPAs to join many of the nation’s largest insurance companies that have already committed to working to expedite adoption of electronic prior authorization and improve the prior authorization system across the entire health care system.

Employer Statement of Support

We, the undersigned self-insured plan sponsors, applaud the Department of Health and Human Services (HHS), the Centers for Medicare & Medicaid Services (CMS), and the insurance companies participating in the Prior Authorization Pledge for their vision and commitment to improve existing prior authorization mechanisms. Self-insured employers often utilize the platforms and services of insurance companies to process claims and administer prior authorization on behalf of self-insured plans. Many of the specified reforms, in particular those involving the establishment of more efficient, transparent, and interoperable electronic prior authorization processes, would result in improved prior authorization processes for self-insured employers if their plans are administered on these new platforms, which we expect to be available immediately. But other reforms, including changes to the services subject to prior authorization, could be adopted on a plan-by-plan basis, and we wish to ensure that participating insurance carriers/third-party administrators (TPAs) and other service providers make such reforms available to self-insured plan sponsors for consideration and adoption into their plan design and administration.

As self-insured plan sponsors with obligations under the Employee Retirement Income Security Act of 1974 (ERISA), plan fiduciaries must ensure that they are prudent stewards of plan assets and resources and are administering their plan in the best interests of plan participants and beneficiaries in accordance with plan documents and applicable laws and regulations.

The reforms specified in the Prior Authorization Pledge may be important tools and capabilities for self-insured plan sponsors to adopt into the design and administration of their plans to better effectuate any applicable prior authorization and for consideration as to whether reductions and other reforms of prior authorization may align with their specific circumstances and responsibilities under ERISA.

Again, we applaud and support HHS/CMS and the current pledge participants and urge them to make the technical improvements and other capabilities they are developing under the Prior Authorization Pledge immediately available to self-insured ERISA health plan sponsors.

Statement of Support Signatories

Amazon
Axon Enterprise, Inc.
Google
Meta
Oracle Corporation

If you would like to sign-on to the Statement of Support, please contact ePAPledgeEmployers@cms.hhs.gov.