AASM submits comments on CMS interoperability and prior authorization proposed rule

On April 14, 2026, the Centers for Medicare & Medicaid Services (CMS) published the Interoperability Standards and Prior Authorization for Drugs Proposed Rule, representing a significant step toward modernizing prior authorization processes and expanding interoperability across the healthcare system. These efforts directly affect sleep medicine practices and patient outcomes.

AASM submitted comments in response to the proposed rule, strongly supporting the agency’s efforts to improve interoperability and digitize prior authorization through standardized electronic processes. The AASM highlighted that electronic prior authorization and application programming interface (API)-based data exchange have the potential to reduce care delays, improve workflow efficiency, and enhance care coordination, particularly for patients requiring sleep testing, positive airway pressure (PAP) therapy, medications, and other sleep-related interventions. At the same time, AASM urged CMS to ensure that implementing these requirements is feasible for specialty practices, as many sleep medicine professionals operate in small or resource-constrained settings.

AASM’s comments emphasized the need for meaningful improvements in prior authorization policies, including:

• Expansion of electronic prior authorization for drugs across both medical and pharmacy benefits to reduce fragmented, manual processes
• Clear and consistent decision timeframes, including expedited pathways for clinically urgent therapies, such as treatments for narcolepsy and hypersomnia
• Greater transparency in denials, with specific explanations tied to clinical criteria and documentation requirements\
• Public reporting of prior authorization metrics to improve accountability across payers

AASM also called on CMS to ensure that new interoperability requirements support the unique needs of sleep medicine. This includes enabling the exchange of clinically relevant data, such as polysomnography reports, home sleep apnea test results, PAP adherence data, and validated questionnaires, through standardized APIs. AASM’s comments underscore that successful implementation of this rule will depend on ensuring that interoperability and prior authorization reforms are not only technologically robust, but also clinically practical and aligned with specialty care workflows.

Members may submit questions about the proposed rule or the AASM response to coding@aasm.org.