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UW Health Urges CMS to Enhance Standardization and Efficiency in Prior Authorization Process
Carter Struck
WASHINGTON, June 27 -- UW Health, an integrated health system and academic medical center based in Madison, Wisconsin, has submitted a public comment letter to the Centers for Medicare & Medicaid Services regarding the proposed rule on Medicare and Medicaid Programs' prior authorization for drugs.
Alan S. Kaplan, CEO of the health system, supports CMS's efforts to modernize prior authorization through electronic processes and standardized data exchange, highlighting the potential to reduce manual administrative burdens and accelerate care access.
UW Health remarks on existing operational challenges
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WASHINGTON, June 27 -- UW Health, an integrated health system and academic medical center based in Madison, Wisconsin, has submitted a public comment letter to the Centers for Medicare & Medicaid Services regarding the proposed rule on Medicare and Medicaid Programs' prior authorization for drugs.
Alan S. Kaplan, CEO of the health system, supports CMS's efforts to modernize prior authorization through electronic processes and standardized data exchange, highlighting the potential to reduce manual administrative burdens and accelerate care access.
UW Health remarks on existing operational challengescaused by payer variability in data formatting and denial responses, indicating that inconsistent systems require repetitive submissions and manual follow-ups that hinder workflow efficiency. The organization endorses CMS's proposal for requiring specific reasons for denials and encourages the agency to promote payer alignment through common denial codes and operational consistency.
The letter also backs CMS's proposed timelines for prior authorization decisions, emphasizing that current delays exceeding 21 days adversely affect treatment for complex medical cases. UW Health underscores that the proposed 24-hour decision window for drug-related authorizations could significantly improve patient outcomes by fostering automation.
Further, UW Health calls for advancements in step therapy protocols by encouraging the use of interoperable electronic data to transmit prior treatment history across payers. This, it argues, would reduce redundant documentation and clarify definitions related to therapy trials and failures.
The health system concludes by affirming strong support for the rule's goals while urging continued CMS engagement to enhance the effectiveness and operational feasibility of the prior authorization process.
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Read full text of letter here: https://www.regulations.gov/comment/CMS-2026-1255-0310
Ohio Community Health Centers Urge Enhanced CMS Standards for Drug Prior Authorization Interoperability
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WASHINGTON, June 27 -- The Ohio Association of Community Health Centers, representing 61 Federally Qualified Health Centers and FQHC Look-Alikes across Ohio, submitted a public comment letter to the Centers for Medicare & Medicaid Services addressing the proposed updates to Medicare and Medicaid programs regarding interoperability standards and prior authorization for drugs.
Headquartered in Columbus, Ohio, OACHC advocated for reforms that would reduce administrative burdens on Community Health Centers while improving timely patient access to medically necessary care.
The letter, signed by President
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WASHINGTON, June 27 -- The Ohio Association of Community Health Centers, representing 61 Federally Qualified Health Centers and FQHC Look-Alikes across Ohio, submitted a public comment letter to the Centers for Medicare & Medicaid Services addressing the proposed updates to Medicare and Medicaid programs regarding interoperability standards and prior authorization for drugs.
Headquartered in Columbus, Ohio, OACHC advocated for reforms that would reduce administrative burdens on Community Health Centers while improving timely patient access to medically necessary care.
The letter, signed by Presidentand CEO Julie DiRossi-King, emphasized that CHCs serve medically underserved populations and provide integrated care at over 600 sites in 76 Ohio counties. The association highlighted that prior authorization delays frequently interrupt treatment and impose barriers to stable health outcomes, noting that the current system is fragmented and burdensome.
They supported CMS' goal to modernize interoperability and implement electronic prior authorization (ePA) systems that enhance standardized, real-time data exchange among payers, providers, and health IT systems. Such improvements could decrease duplicative documentation requests and streamline care coordination for CHC patients who often navigate multiple payers, hospitals, and specialists.
While praising the proposal's potential to improve access and administrative efficiency, OACHC called on CMS to ensure implementation includes vendor readiness and operational consistency. Since CHCs often depend on limited EHR vendors and IT resources, the group urged CMS to clarify that providers would not be penalized for technology failures beyond their control. They recommended coordinated timelines with the Office of the National Coordinator for Health IT (ONC) certification requirements, along with validation or testing before enforcement, to avoid disruption and fragmentation across payers.
OACHC strongly supported extending ePA requirements to all drugs needing prior authorization, highlighting that this change could improve prescribing decision-making during patient encounters and reduce treatment delays. Given CHCs' patient populations-with millions managing diabetes, hypertension, obesity, and behavioral health conditions-timely medication access is crucial to prevent complications. The association also requested that CMS require payers to provide real-time benefit classification information to distinguish pharmacy from medical benefits, reducing confusion for clinic-administered drugs and facilitating accurate claims processing.
Addressing concerns about pharmacy operations, OACHC urged CMS to coordinate with the Office of Pharmacy Affairs to provide technical assistance and funding to help CHCs manage complex workflows involving 340B contract pharmacies, third-party administrators, and pharmacy management systems. The association noted interoperability challenges persist, including limited EHR integration and misaligned data standards, which could delay medication access and increase errors without proper support.
OACHC advocated for mandatory proactive notifications of PA expiration via FHIR-based alerts to help avoid treatment interruptions and administrative burdens associated with retroactive reauthorization. They cautioned that ePA technology alone will not reduce overall administrative burdens unless paired with prior authorization reforms such as gold-carding for high approval rate categories and sunset provisions to eliminate unnecessary PA.
In support of CMS' efforts to standardize PA decision timelines, OACHC backed requirements for rapid PA determinations: 24 hours for covered outpatient drugs, seven days for standard requests, and 72 hours for expedited requests. They emphasized such uniform timeframes would reduce treatment delays that disproportionately affect medically underserved CHC patients facing access barriers.
OACHC also endorsed CMS' proposal to require detailed denial reasons on drug PA denials for all submission methods. This transparency would allow CHCs to correct incomplete requests and pursue appeals more efficiently, reducing delays in care. Moreover, the group supported improved public reporting of PA metrics on CMS' website, recommending expanded data capture to reflect real-world administrative burdens and stronger oversight to ensure payer accountability. They proposed automatic approval of PA requests not decided within required deadlines as an enforcement mechanism to safeguard patient access.
The association welcomed CMS' plans to publish payer API endpoint information centrally, easing technical access challenges for CHCs' limited IT staff and promoting operational efficiency. OACHC expressed support for aligned metrics reporting on API usage by Medicaid managed care plans and CHIP entities, highlighting that disaggregated data would help target improvement efforts for populations constituting nearly half of CHC patients.
OACHC urged CMS to reconsider proposals to remove drug formulary information from Provider Access and Payer-to-Payer APIs, cautioning that inconsistent access to current formulary data forces CHCs to conduct manual lookups across multiple payers. Retaining formulary data in APIs would enhance prescribing efficiency and transparency.
Acknowledging financial pressures on CHCs, including precarious operating margins and workforce constraints, the association urged CMS to prioritize safety-net providers for federal funding opportunities and provide transition support during the shift from legacy X12 standards to modern FHIR-based exchanges. OACHC advocated extending enforcement discretion to avoid penalties during overlapping compliance periods affecting provider IT systems.
In recommending policies for Clinical Data Exchange (CDex) used for PA attachments, OACHC called for limits on iterative data requests and requirements for payers to specify all needed documentation up front to prevent administrative overload.
The association supported gold-carding initiatives that would exempt compliant providers from redundant prior authorizations, emphasizing that such approaches reduce time and costs while improving patient access to care. They also requested CMS and ONC coordinate to ensure health IT certification programs align with CMS' interoperability requirements, noting concerns about potential conflicts between proposed rules that could affect vendor priorities and operational readiness in safety-net settings.
In summary, OACHC endorsed CMS' interoperability and ePA proposals as promising reforms to reduce barriers to medication access and streamline prior authorization processes for community health settings. However, they stressed the need for realistic timelines, national standards harmonization, robust vendor accountability, targeted technical support, and safety-net provider funding to ensure successful implementation without compromising care for medically underserved populations.
The association remains open to further dialogue with CMS to refine these regulations and enhance healthcare access and equity for millions served by Ohio's Community Health Centers and similar providers nationwide.
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Read full text of letter here: https://www.regulations.gov/comment/CMS-2026-1255-0302
National Psoriasis Foundation Urges Patient-Centered Reforms to Medicare and Medicaid Prior Authorization Policies
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WASHINGTON, June 27 -- The National Psoriasis Foundation, Alexandria, Virginia, has submitted a public comment letter to the Centers for Medicare & Medicaid Services addressing the agency's proposed rule on interoperability standards and prior authorization for drugs under Medicare Advantage, Medicaid, the Children's Health Insurance Program, and Qualified Health Plans on federally-facilitated exchanges. The NPF advocates for the roughly 8 million Americans living with psoriatic disease and seeks to influence policies impacting timely and accessible treatment for this complex, chronic condition.
In
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WASHINGTON, June 27 -- The National Psoriasis Foundation, Alexandria, Virginia, has submitted a public comment letter to the Centers for Medicare & Medicaid Services addressing the agency's proposed rule on interoperability standards and prior authorization for drugs under Medicare Advantage, Medicaid, the Children's Health Insurance Program, and Qualified Health Plans on federally-facilitated exchanges. The NPF advocates for the roughly 8 million Americans living with psoriatic disease and seeks to influence policies impacting timely and accessible treatment for this complex, chronic condition.
Inits letter to CMS, the NPF expresses support for continued efforts to streamline the prior authorization process, particularly the transition to electronic prior authorization for drugs, standardized communication protocols, expanded visibility through application programming interfaces (APIs), and enhanced transparency with public reporting requirements. The organization emphasizes that prior authorization requirements, including utilization management tools like step therapy, often create administrative barriers that delay or disrupt care for patients with psoriatic disease. Research cited by the NPF identifies substantial delays in treatment access and increased disease progression linked to prior authorization burdens in this patient population.
The foundation urges CMS to finalize the proposed policies with several patient-centered improvements. Key recommendations include clarifying that the goal of electronic prior authorization should be to foster a process that is timely, predictable, and navigable-not merely a digital replication of a burdensome system. They caution against broad exceptions and extension mechanisms within the rule, advocating that any such allowances be narrowly defined, transparent, and temporary to avoid perpetuating disparities in access among different insurance programs.
NPF applauds the agency's intent to align decision-making timelines across programs, supporting the proposal that Medicaid and CHIP entities respond within 24 hours and QHP issuers complete decisions within 72 hours under normal circumstances, accelerating to 24 hours in emergencies. The organization underscores the urgency of expeditious decisions given psoriatic disease's systemic inflammation and related increased risks for mortality and multiple comorbidities such as cardiovascular disease and diabetes. The need for prompt treatment is not only a quality-of-life issue but a critical factor in preventing serious downstream health consequences.
Equally important, the NPF asserts that denial communications from insurers must be detailed, timely, and practical for both clinicians and patients. Rather than vague explanations that coverage criteria were unmet, denials should specify the exact reasons, such as missing documentation or failure to meet certain clinical criteria, and outline actionable next steps for appeal or resubmission. Patient communications should be clear and accessible, addressing diverse literacy levels and caregiving contexts to enable patients to understand what was denied, why, and how to proceed.
The foundation further stresses the necessity for the electronic prior authorization system to promote continuity of care, particularly important for patients who frequently change plans, receive medications through various benefit programs, or coordinate among multiple providers and caregivers. The NPF recommends that CMS closely monitor real-world impacts of the finalized policies to ensure that timelines, communication, and interoperability truly enhance timely access and seamless treatment.
To assess the effectiveness of reforms, the NPF supports CMS's proposal to establish centralized public reporting mechanisms for API use and prior authorization metrics. They highlight the importance of including data on repeated resubmissions, plan inconsistencies, frequent use of extensions, unclear denial rationales, and patterns among patients with chronic or rare diseases. Transparent, comprehensive data will help identify systemic issues and guide further improvements.
Regarding step therapy, the NPF advocates for clear and standardized exceptions processes that recognize prior payer determinations to prevent patients from unnecessarily repeating ineffective or harmful treatment steps. They recommend rulemaking to mandate that payers respond to exception requests within 72 hours under normal circumstances and 24 hours in emergencies, granting exceptions under conditions such as prior treatment failure, expected ineffectiveness, risk of harm, or when a patient is stable on their current medication. The foundation further urges CMS to prohibit payers from forcing patients to restart step therapy protocols already navigated with previous insurers, even if prior and current step requirements differ.
Additionally, the NPF draws attention to challenges related to prior authorization for laboratory testing, urging CMS to align policies with real-world workflows. The letter points out that authorization denials based solely on timing of specimen collection versus processing can cause unnecessary repeat blood draws, treatment delays, psychological distress, and logistical burdens, particularly for rural patients. The foundation calls on CMS to require health plans to prohibit timing-based denials, prevent redundant testing when viable specimens exist, standardize documentation acceptance, and protect patients from surprise bills when all parties act in good faith.
Overall, the National Psoriasis Foundation endorses many elements of CMS's proposed rule but highlights essential refinements to ensure the reforms translate into tangible patient benefits. Their advocacy emphasizes expeditious and transparent prior authorization decisions, standardized and fair step therapy protocols, interoperability that facilitates continuity of care, and data-driven accountability. The NPF conveyed their availability to further discuss these priorities with CMS, signaling ongoing engagement to improve health outcomes for those affected by psoriatic disease under federal health programs.
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Jason Harris
Vice President, Government Relations and Advocacy
National Psoriasis Foundation
1800 Diagonal Rd., Suite 360 | Alexandria, VA 22314
psoriasis.org
Read full text of letter here: https://www.regulations.gov/comment/CMS-2026-1255-0300
National Council for Mental Wellbeing Supports CMS Proposed Changes to Improve Drug Prior Authorization Processes
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WASHINGTON, June 27 -- The National Council for Mental Wellbeing, Alexandria, Virginia, submitted a public comment letter to the Centers for Medicare & Medicaid Services regarding its proposed rule on interoperability standards and prior authorization for drugs under Medicare Advantage, Medicaid managed care plans, CHIP programs, and Qualified Health Plans on the Federally-Facilitated Exchanges.
The letter, signed by Reyna Taylor, Senior Vice President, Public Policy & Advocacy, highlighted the importance of the protected classes policy within Medicare Part D, which ensures that patients with
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WASHINGTON, June 27 -- The National Council for Mental Wellbeing, Alexandria, Virginia, submitted a public comment letter to the Centers for Medicare & Medicaid Services regarding its proposed rule on interoperability standards and prior authorization for drugs under Medicare Advantage, Medicaid managed care plans, CHIP programs, and Qualified Health Plans on the Federally-Facilitated Exchanges.
The letter, signed by Reyna Taylor, Senior Vice President, Public Policy & Advocacy, highlighted the importance of the protected classes policy within Medicare Part D, which ensures that patients withcomplex mental health conditions can access all or substantially all medications in the six protected classes, including antidepressants and antipsychotics. It expressed support for CMS efforts to create a more transparent and efficient prior authorization process, noting that such changes have the potential to reduce administrative burdens and improve timely patient access.
CMS's proposal to require state Medicaid and CHIP programs, managed care plans, and Qualified Health Plan issuers to provide specific reasons for denying prior authorization requests was particularly praised as a step toward enhancing communication and care continuity. The National Council also commended CMS's push to modernize interoperability infrastructure by standardizing application programming interfaces (APIs) and improving electronic prior authorization.
However, the organization raised concerns about provider readiness, emphasizing that mental health and substance use providers often lack the financial and technical resources to adapt quickly. It urged CMS to clarify that providers would not face penalties for vendor-related failures and called for coordinated implementation with the Office of the National Coordinator for Health IT to ensure consistent application.
Additionally, the National Council cautioned against increased cybersecurity risks due to expanded electronic data exchange, particularly given the limited resources of many providers. It recommended that CMS provide technical assistance, funding, and workforce development to support safe implementation without compromising patient care.
These comments underline the need for balanced policies that enhance drug access and data interoperability while addressing the operational realities of mental health providers.
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Read full text of letter here: https://www.regulations.gov/comment/CMS-2026-1255-0304
Hidalgo Soil and Water Conservation District Supports BLM Grazing Regulation Revisions
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WASHINGTON, June 27 -- The Hidalgo Soil and Water Conservation District, Lordsburg, New Mexico, has submitted a public comment letter to the U.S. Bureau of Land Management regarding proposed revisions to grazing regulations.
The conservation district letter, signed by John Samuel, President and Members of the Board of Supervisors, endorses broader application of land health standards across all BLM programs, highlighting the need for balanced management of rangeland health factors including wildfire and invasive species.
The letter emphasizes the importance of operational flexibility for permittees
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WASHINGTON, June 27 -- The Hidalgo Soil and Water Conservation District, Lordsburg, New Mexico, has submitted a public comment letter to the U.S. Bureau of Land Management regarding proposed revisions to grazing regulations.
The conservation district letter, signed by John Samuel, President and Members of the Board of Supervisors, endorses broader application of land health standards across all BLM programs, highlighting the need for balanced management of rangeland health factors including wildfire and invasive species.
The letter emphasizes the importance of operational flexibility for permitteesto adapt to drought and wildfire recovery, promoting soil and water conservation through managed grazing.
Additionally, the district supports improvements to the appeals process to maintain stability in stewardship practices.
The letter calls for cooperative monitoring and stronger collaboration with local conservation districts, advocating for sustainable management that protects soil and water resources while supporting rural economies.
The Hidalgo Soil and Water Conservation District urges the BLM to finalize the rule to enhance multiple-use public land management.
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Read full text of letter here: https://www.regulations.gov/comment/BLM-2026-0001-0162
Colorado Conservation Districts Urge BLM to Align Grazing Regulations With Local Land Use Policies
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WASHINGTON, June 27 -- The White River and Douglas Creek Conservation Districts, based in Meeker, Colorado, provided a public comment letter to the U.S. Bureau of Land Management regarding proposed revisions to grazing administration regulations outside of Alaska.
The Districts emphasized the importance of grazing on public lands to the ranching community in Rio Blanco County.
They highlighted their Land & Natural Resource Use Plan and Policy (LNRPP), which directs local land management strategies and stresses government-to-government consultation during federal decision-making processes.
The
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WASHINGTON, June 27 -- The White River and Douglas Creek Conservation Districts, based in Meeker, Colorado, provided a public comment letter to the U.S. Bureau of Land Management regarding proposed revisions to grazing administration regulations outside of Alaska.
The Districts emphasized the importance of grazing on public lands to the ranching community in Rio Blanco County.
They highlighted their Land & Natural Resource Use Plan and Policy (LNRPP), which directs local land management strategies and stresses government-to-government consultation during federal decision-making processes.
Theletter, signed by White River President Chris Collins and Douglas Creek President, urged the BLM to ensure timely and efficient permit renewals, including use of categorical exclusions when appropriate, and to adopt flexible and adaptive grazing management practices.
The conservation districts also advocated that authorized grazing animal unit months should only be reduced temporarily when resource conditions require it and that grazing be used as a tool for vegetation management and fuel load reduction.
The letter called on the BLM to consider local economic impacts and multiple-use management objectives in its rulemaking for Rio Blanco County lands.
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Read full text of letter here: https://www.regulations.gov/comment/BLM-2026-0001-0163
AMGA Urges CMS to Accelerate Drug Prior Authorization Timelines and Improve Provider Access
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WASHINGTON, June 27 -- The American Medical Group Association, Alexandria, Virginia, representing more than 440 multispecialty medical groups and integrated delivery systems, issued a public comment letter to the Centers for Medicare & Medicaid Services addressing the agency's 2026 proposed rule on interoperability standards and prior authorization for drugs.
The letter, signed by Jerry Penso, president and CEO, highlighted the clinical challenges and administrative burdens imposed by current prior authorization processes and proposed several changes to enhance patient access, reduce provider
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WASHINGTON, June 27 -- The American Medical Group Association, Alexandria, Virginia, representing more than 440 multispecialty medical groups and integrated delivery systems, issued a public comment letter to the Centers for Medicare & Medicaid Services addressing the agency's 2026 proposed rule on interoperability standards and prior authorization for drugs.
The letter, signed by Jerry Penso, president and CEO, highlighted the clinical challenges and administrative burdens imposed by current prior authorization processes and proposed several changes to enhance patient access, reduce providerworkload, and standardize procedures across payers.
AMGA acknowledged CMS's effort to extend interoperability frameworks to prescription drugs, particularly specialty and provider-administered therapies that frequently require prior authorization. The association advocated for shortening the standard decision timeframe for drug prior authorization requests submitted by Qualified Health Plan issuers on the Federally Facilitated Exchanges from 72 to 24 continuous hours. The recommendation includes harmonizing this timeline across all payers, including Medicare Advantage and Medicaid managed care plans, to match the urgency of clinical care regardless of coverage type.
The association emphasized that prior authorization decisions currently measured in business or calendar days often result in delays when requests span weekends, potentially obstructing timely access to necessary treatments such as chemotherapy, biologic infusions, or medications prescribed upon hospital discharge. AMGA argued that provider offices operate continuously and that authorization processes should reflect this reality to avoid gaps in care during weekends or holidays.
A key proposal was to institute a default-to-approval policy whereby any prior authorization request not adjudicated within the specified timeframe would be automatically deemed approved. AMGA cited Medicare Advantage data indicating that approximately 92% of prior authorization requests are initially approved, and many denials that are appealed are overturned. The association pointed out that without consequences for missing deadlines, payers lack incentives to comply, transferring the burden and delay to providers and patients, sometimes with serious clinical repercussions.
AMGA also urged CMS to broaden the Provider Access Application Programming Interface to include all providers with a demonstrable care relationship with the patient, irrespective of network status. The association expressed concern that limiting access to contracted providers can produce incomplete medication histories and fragmented care, especially for patients with complex conditions relying on multiple specialists in various networks. By extending access, providers would better coordinate care, reduce duplicative administrative tasks, and improve outcomes, particularly in underserved communities where out-of-network care is more common.
The organization recommended establishing a "Gold Carding" framework that exempts providers from prior authorization requirements when they demonstrate consistently high approval rates, such as a 90% or higher drug prior authorization approval rate over six months. Drawing on successful state-level examples, AMGA suggested automatic application of this status based on existing approval data and proposed extending full exemptions from step therapy protocols to providers engaged in risk-bearing value-based arrangements. According to AMGA, this approach aligns with value-based care principles by reducing unnecessary administrative burdens while maintaining appropriate utilization oversight.
To improve transparency and reduce re-work, the group encouraged CMS to require minimum content standards for denial notices. These notices should clearly identify the specific unmet clinical criteria, detail the documentation required for approval, cite the relevant plan policies or clinical guidelines, and be delivered electronically in a structured, machine-readable format via the Prior Authorization API. AMGA emphasized that vague or boilerplate denial reasons hinder providers' ability to respond efficiently to authorization requests.
Addressing value-based care models, AMGA advocated for exemptions from prior authorization requirements for providers participating in arrangements where they bear financial responsibility for outcomes and costs. The association urged CMS to gather data on the volume and cost of prior authorization within such arrangements and to create regulatory pathways for future exemptions. This recommendation reflects an effort to align prior authorization practices with incentives for high-value care and accountability.
Additionally, AMGA recommended that CMS consider extending electronic prior authorization processes, including decision timelines and denial transparency standards, to laboratory tests and durable medical equipment, prosthetics, orthotics, and supplies. These areas pose similar administrative challenges and are critical components of comprehensive care, especially in primary care, oncology, and post-acute care settings.
AMGA concluded by commending CMS for advancing prior authorization transparency and interoperability and requested the agency finalize the rule incorporating the proposed modifications. The association emphasized the potential of these reforms to create a more efficient, patient-centered prior authorization system that prioritizes timely access to medically necessary treatments while reducing undue burdens on providers and patients.
The letter reflected AMGA's broader commitment to prior authorization reform and health system modernization. The organization expressed readiness to collaborate with CMS on future rulemaking and policy development to further streamline processes in pursuit of equitable and high-quality care.
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Read full text of letter here: https://www.regulations.gov/comment/CMS-2026-1255-0309
American Dental Association Urges CMS to Tailor Prior Authorization and Interoperability Standards for Dentistry
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WASHINGTON, June 27 -- The American Dental Association, Chicago, Illinois, submitted a public comment letter to the Centers for Medicare & Medicaid Services regarding the proposed rule aimed at enhancing interoperability standards and prior authorization processes across Medicare Advantage organizations, Medicaid plans, CHIP agencies, and qualified health plan issuers on federally-facilitated exchanges.
The letter, co-signed by President Richard J. Rosato and Executive Director Nader A. Nadershahi, commended CMS for its efforts to streamline prior authorization and promote secure information
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WASHINGTON, June 27 -- The American Dental Association, Chicago, Illinois, submitted a public comment letter to the Centers for Medicare & Medicaid Services regarding the proposed rule aimed at enhancing interoperability standards and prior authorization processes across Medicare Advantage organizations, Medicaid plans, CHIP agencies, and qualified health plan issuers on federally-facilitated exchanges.
The letter, co-signed by President Richard J. Rosato and Executive Director Nader A. Nadershahi, commended CMS for its efforts to streamline prior authorization and promote secure informationexchange but emphasized the need to consider the unique characteristics of dental practice and infrastructure to ensure successful implementation.
The ADA highlighted that the adoption of standardized application programming interfaces (APIs) has the potential to improve information exchange at the point of care, increase efficiency, and reduce administrative burdens for providers, particularly benefiting medically complex and low-income patients requiring dental services. Nevertheless, the association cautioned that dental practices often operate in small, specialty, or single-site environments with limited IT support, which distinguishes them from larger medical health systems and poses risks for uneven adoption if implementation requirements are primarily calibrated to medical settings.
According to the ADA, administrative efficiencies will depend on standards that work consistently across medical, standalone dental benefit plans, pharmacy benefit managers, and vendors supporting dental providers. Without dental-specific testing, phased adoption, and technical assistance, dental providers could face added administrative duties and patient care delays. The association applauded CMS's intention to enable faster prior authorization decisions and greater transparency but urged that dental realities be embedded into the design.
The letter described several challenges in current dental workflows, such as redundant data entry across multiple payer portals, late discovery of prior authorization requirements, and the frequent need to manually assemble and resend detailed attachments including radiographs, periodontal charts, and tooth-specific information. The ADA detailed how standardized APIs could shift these requirements "upstream," providing coverage and documentation expectations directly within existing dental practice systems, and reducing phone calls and portal switching.
The ADA recommended that CMS explicitly test and validate API standards for dentistry through pilots involving solo, small-group, oral surgery practices, and dental service organizations before enforcing mandates affecting dental workflows. These pilots should ensure dental data elements like Current Dental Terminology (CDT) codes, oral anatomy including tooth numbering and surface information, imaging, and periodontal measurements are fully represented and computable. They should also confirm workflows support coordination between dental and medical payers and that implementations are feasible for vendors serving smaller practices rather than solely enterprise-level electronic health record systems.
The association also pointed out that dentistry often relies on "pre-determination" or "pre-treatment estimates" rather than solely on medical necessity-based prior authorizations typical in medical care. Current FHIR (Fast Healthcare Interoperability Resources) profiles referenced in the proposed rule are not yet mature enough to adequately represent dental-specific workflows, coding, or imaging exchange. As a result, the ADA urged CMS to collaborate with standards development organizations to advance dental-specific FHIR implementation guides prior to broad enforcement.
Electronic prior authorization (ePA) for drugs was raised as an especially complex area for dentistry, particularly concerning medications used in oral surgery and anesthesia. The ADA explained that many dental-prescribed medications do not fit neatly into existing definitions of "medical benefit" or "pharmacy benefit," complicating applicability under proposed standards. The association advocated for clear CMS guidance addressing these nuances, including recognition of dental anesthesia coding differences and treatment setting variations affecting drug classification. It noted limited current integration of pharmacy-related standards like the National Council for Prescription Drug Programs (NCPDP) Formulary & Benefit and Real-Time Prescription Benefit tools into dental practice management systems.
The ADA stressed the importance of including standalone dental plans (SADPs) within interoperability and prior authorization frameworks to avoid perpetuating fragmentation and administrative burden, while suggesting a tailored and phased implementation approach accounting for dental market characteristics and vendor readiness. Recommendations included delayed compliance timelines, accommodation of dental-specific workflow needs, collaboration on standards refinement, and pilot programs prior to mandatory compliance.
Regarding proposed modifications to HIPAA standards involving a shift from X12 278 to FHIR-based prior authorization transactions, the ADA voiced concerns about readiness among dental providers, payers, clearinghouses, and software vendors. The association noted most dental practice management systems lack native FHIR endpoints and do not participate in certification programs akin to medical electronic health records, creating an ecosystem accountability gap. Given financial pressures and limited administrative capacity in dental settings, especially rural and underserved communities, rapid system transitions risk disrupting patient access and adding costs. The ADA urged for phased adoption, real-world testing, and aligned compliance timelines.
The letter observed that some dental software platforms function in ways similar to health information networks yet remain outside certification and information blocking rules, reducing incentives to enable interoperability and API access. It recommended CMS engage in structured dialogue with ONC, state Medicaid agencies, dental stakeholders, and vendors to explore mechanisms for aligning dental software with interoperability standards.
The ADA further expressed support for electronic event notifications to improve care coordination, particularly by alerting dental providers when patients visit emergency departments for dental-related conditions. This functionality can facilitate timely follow-up, reduce inappropriate ED use, and promote medical-dental integration by closing communication gaps.
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Read full text of letter here: https://www.regulations.gov/comment/CMS-2026-1255-0308
American Academy of Allergy Asthma and Immunology Highlights Challenges in Drug Prior Authorization
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WASHINGTON, June 27 -- The American Academy of Allergy Asthma and Immunology issued a public comment letter to the Centers for Medicare and Medicaid Services and the Office of the National Coordinator for Health Information Technology. The letter addresses the proposed rule on interoperability standards and prior authorization for drugs.
The AAAAI supported efforts to modernize prior authorization through electronic standards but emphasized that benefits will be limited without integrated systems bridging medical and pharmacy benefits. The letter, signed by President Carla M. Davis, noted that
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WASHINGTON, June 27 -- The American Academy of Allergy Asthma and Immunology issued a public comment letter to the Centers for Medicare and Medicaid Services and the Office of the National Coordinator for Health Information Technology. The letter addresses the proposed rule on interoperability standards and prior authorization for drugs.
The AAAAI supported efforts to modernize prior authorization through electronic standards but emphasized that benefits will be limited without integrated systems bridging medical and pharmacy benefits. The letter, signed by President Carla M. Davis, noted thatmany allergy and immunology therapies, including biologics for severe asthma and immunologic conditions, may shift between benefit categories depending on administration methods and payer policies. This fragmentation causes treatment delays, interruptions, patient confusion over cost-sharing, and operational challenges for providers.
The organization encouraged CMS and ONC to develop an interoperability framework that unifies access to coverage, formulary, prior authorization, and utilization management criteria across benefit types. AAAAI also backed proposals aimed at improving transparency in prior authorization denials and public reporting of metrics, urging even more specific reporting at the drug level to identify barriers to access.
On decision timeframes, AAAAI recommended establishing a uniform 24-hour maximum response for prior authorization requests for allergy/immunology prescriptions to prevent adverse health outcomes from treatment delays. The group supported including prior authorization information in various APIs but opposed removing drug formulary details from Provider Access and Payer-to-Payer APIs, citing the critical role of such information in coordinating care.
AAAAI highlighted the impact of repeated step therapy requirements and utilization management differences on treatment continuity, urging interoperability tools to facilitate access to prior authorization history to reduce administrative burden. The organization stressed that clinical judgment remains essential in coverage decisions for complex cases.
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Read full text of letter here: https://www.regulations.gov/comment/CMS-2026-1255-0299
Agadia Systems Urges CMS to Enhance Prior Authorization Interoperability and Provider Participation
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WASHINGTON, June 27 -- Agadia Systems Inc., Buffalo Grove, Illinois, has submitted a public comment letter to the Centers for Medicare & Medicaid Services addressing proposed rules on interoperability standards and prior authorization processes for drugs. The letter provides detailed feedback on a rule intended to standardize electronic prior authorization workflows, reduce administrative burdens, and improve timely patient access to medications across Medicaid, CHIP, and Qualified Health Plans.
Agadia Systems expresses strong support for CMS's proposed benefit-based approach, which differentiates
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WASHINGTON, June 27 -- Agadia Systems Inc., Buffalo Grove, Illinois, has submitted a public comment letter to the Centers for Medicare & Medicaid Services addressing proposed rules on interoperability standards and prior authorization processes for drugs. The letter provides detailed feedback on a rule intended to standardize electronic prior authorization workflows, reduce administrative burdens, and improve timely patient access to medications across Medicaid, CHIP, and Qualified Health Plans.
Agadia Systems expresses strong support for CMS's proposed benefit-based approach, which differentiateselectronic prior authorization workflows depending on whether a drug falls under a medical benefit or a pharmacy benefit. The company highlights that this framework aligns with how payers currently govern prior authorization processes across varying plans and populations. By allowing flexibility rather than enforcing a strict technical classification, CMS accommodates operational diversity and payer adaptability, which are key to minimizing erroneous submissions and delays in care.
In particular, the company endorses CMS's proposal to extend the Fast Healthcare Interoperability Resources (FHIR)-based Prior Authorization API to medical-benefit drugs using implementation guides such as Coverage Requirements Discovery (CRD), Document Templates and Rules (DTR), and Prior Authorization Support (PAS). Agadia emphasizes that maintaining flexibility in signaling benefit classifications within these APIs is essential to reflect diverse payer system architectures and evolving benefit designs. This flexibility is instrumental in enabling payers to achieve outcomes focused on clear documentation expectations, electronic submission, and transparent prior authorization decisions.
For drugs covered under pharmacy benefits, Agadia concurs with CMS's initiative to align Medicaid, CHIP, and Qualified Health Plan requirements with Medicare Part D standards, including the use of National Council for Prescription Drug Programs (NCPDP) SCRIPT, Formulary & Benefit (F&B), and Real-Time Prescription Benefit (RTPB) standards. The company notes that the F&B standard serves as a high-level reference for formulary management rather than a real-time feed, underlining the importance of sound governance practices such as effective date clarity and version control to maintain accuracy and compliance.
Agadia also advocates for CMS's proposal that mandates payers provide specific and meaningful explanations when drug prior authorization requests are denied. Clear denial reasons are viewed as fundamental to reducing unnecessary resubmissions, delays in care, and administrative burden. The company commends CMS's outcome-based emphasis, which prioritizes clarity and usability over prescriptive formatting, enabling payers to tailor communications consistent with their benefit structures and policies.
Regarding prior authorization decision timeframes, Agadia supports CMS's effort to standardize and potentially shorten timelines across payer programs. The company highlights the prevailing variability in state statutes and managed care contracts that complicates uniform compliance. Clear federal expectations combined with flexible, system-driven workflows are seen as a balanced approach that improves predictability for providers while reducing complexity for payers. Additional sub-regulatory guidance on defining "complete request" criteria is recommended to foster consistent implementation.
Public reporting of drug prior authorization metrics is another area where Agadia recognizes CMS's goal to increase transparency and oversight. The company cautions that raw metrics such as approval rates or turnaround times must be contextualized to account for differences in plan designs, member populations, and statutory frameworks. Agadia suggests including high-level explanatory information alongside published data to enhance interpretability for policymakers, regulators, and other institutional audiences, thereby preventing misleading comparisons and unintended conclusions.
Agadia further supports CMS's proposal to require reporting on interoperability API usage metrics along with establishing a centralized process for payer API endpoint disclosure. The company underscores that leveraging existing payer monitoring and vendor-supported systems will promote accurate and scalable compliance. Centralizing endpoint information is expected to reduce fragmentation and facilitate easier integration for providers and developers while maintaining clear distinctions between payer responsibilities and vendor roles.
A notable concern raised in the letter is the lack of explicit provider participation expectations in the proposed rule. While CMS focuses requirements on payers, Agadia highlights that effective interoperability depends on provider engagement with electronic workflows. The current regulatory framework under HIPAA allows, but does not require, providers to respond electronically to prior authorization requests, which often leads to reliance on manual or portal-based processes. This disconnect blunts the potential efficiency gains from payer-side interoperability investments. To address this, Agadia recommends CMS consider policies or incentives that encourage or establish baseline expectations for provider responsiveness, such as integration with certified electronic health record systems, alignment with ONC health IT certification criteria, or clarifying acceptable electronic response methods under HIPAA. The company suggests promoting bidirectional and prospective clinical data exchange to reduce manual documentation requests and enable near-real-time adjudication.
Finally, Agadia offers operational insights on health care resiliency, noting that continuity in an interconnected environment depends on design approaches that mitigate the impact of disruptions by enabling alternative workflows, safe queuing, and use of recent data during outages. The company encourages CMS to continue aligning interoperability requirements with established HIPAA Security Rule obligations and to recognize the distinct yet complementary roles of payers and technology vendors in maintaining secure and resilient health care systems.
Agadia concludes by expressing support for CMS's ongoing coordination with federal partners to enhance interoperability and resiliency, while urging further policy refinement to ensure both payers and providers fully participate in electronic prior authorization workflows. These efforts are positioned as critical to fulfilling CMS's goals of reducing administrative burden and improving timely access to care for patients nationwide.
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Read full text of letter here: https://www.regulations.gov/comment/CMS-2026-1255-0305
10 Scientists Urge EPA to Revise Phthalic Anhydride Risk Evaluation Citing Underestimated Health Risks
Carter Struck
WASHINGTON, June 23 -- A coalition of 10 scientists, academics and clinicians submitted a public comment letter challenging the U.S. Environmental Protection Agency's draft risk evaluation for phthalic anhydride. The letter, addressing the EPA's methodologies and conclusions, asserts that the agency's assessment under the Toxic Substances Control Act fails to employ the best available science and underestimates significant health risks posed by the chemical, particularly to workers and susceptible subpopulations.
Phthalic anhydride, an industrial chemical mainly used in manufacturing alkyd resins,
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WASHINGTON, June 23 -- A coalition of 10 scientists, academics and clinicians submitted a public comment letter challenging the U.S. Environmental Protection Agency's draft risk evaluation for phthalic anhydride. The letter, addressing the EPA's methodologies and conclusions, asserts that the agency's assessment under the Toxic Substances Control Act fails to employ the best available science and underestimates significant health risks posed by the chemical, particularly to workers and susceptible subpopulations.
Phthalic anhydride, an industrial chemical mainly used in manufacturing alkyd resins,plasticizers, and coatings, has been evaluated for skin and respiratory sensitization risks by the EPA. However, the comment letter identifies multiple flaws in how the EPA developed toxicity thresholds and accounted for uncertainty and variability in human susceptibility.
Central to the scientists' concern is the EPA's use of the SARA-ICE model-a statistical method co-developed by the National Toxicology Program and Unilever-to establish a point of departure (POD) for skin sensitization. The letter critiques the agency for using a central estimate of the effective dose for a 1% effect (ED01) rather than a more protective estimate that accounts for uncertainty, such as the fifth percentile of the dose distribution. Using a central estimate, the letter argues, results in a POD that places half the population at risk exceeding the 1-in-100 level considered and is inconsistent with standard EPA risk assessment practices.
The letter also challenges the EPA's adoption of a "Data Evaluation Record" (DER) approach for assessing the in vitro and in chemico studies forming the basis of the SARA-ICE inputs. It contends that DERs lack the standardized criteria and critical appraisal metrics necessary for systematic review and risk evaluation consistency, potentially overlooking study limitations. Moreover, the letter reasons that the EPA unjustifiably assumes no uncertainty or variability in the POD estimate from SARA-ICE, despite limited human data underlying the model and extensive evidence supporting a need for larger uncertainty factors to protect sensitive populations.
Respiratory sensitization risks receive similar scrutiny in the letter. While crediting the EPA's acknowledgment of robust evidence from animal and human studies indicating respiratory sensitization, the letter notes that EPA ultimately favored a human worker study POD that is considerably less protective than animal-derived PODs that imply significant effects at 4- to 13-fold lower doses. The commenters emphasize that EPA lacks sufficient scientific justification for discounting the animal data and applying uncertainty factors that do not adequately account for human variability. They cite World Health Organization findings suggesting that EPA's tenfold uncertainty factor for human variability underestimates the true range of responses by healthy adults, let alone more vulnerable groups.
The letter further highlights concerns with EPA's compliance with TSCA mandates regarding oversight of potentially exposed or susceptible subpopulations (PESS). The commenters assert that the EPA's risk evaluation insufficiently identifies and considers PESS, such as infants, pregnant women, workers, and fenceline communities experiencing disproportionate chemical exposure coupled with other stressors. The letter notes that although the EPA's draft evaluation lists some PESS, it omits a consistent framework to identify all potentially vulnerable groups or adjust risk estimates in accordance with scientific consensus on human variability. The commenters argue that reliance on default uncertainty factors dating back several decades fails to capture the enhanced susceptibility observed in many populations experiencing intrinsic and extrinsic risk factors.
The letter also expresses scientific integrity concerns related to EPA's reliance on the SARA-ICE framework, co-developed with a chemical industry entity. It underscores that industry influence introduces potential bias, particularly when evaluating hazard data and risk methodologies. This concern extends to the ad hoc Science Advisory Committee on Chemicals appointed to review the assessment, which is noted to include members with financial ties to the chemical industry. The letter recommends excluding advisory committee members with conflicts of interest to uphold scientific impartiality.
The signatories include scientists from academic institutions such as Stanford University, University of Sydney, University of California San Francisco, and the University of Rhode Island, as well as representatives from allied health advocacy organizations. They advocate for EPA revisions that incorporate a systematic approach to study evaluation, use conservative dose-response metrics consistent with established EPA policy, apply appropriate uncertainty factors to address human variability and susceptibility, and use all relevant animal and human evidence for respiratory sensitization risks.
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The letter was signed by:
Daniel Axelrad, MPP, Independent Consultant, Washington, District of Columbia
Rashmi Joglekar, PhD, Science Policy Director, Stanford University
Abena BakenRa, MPH, Science Policy Analyst, Stanford University
Emily Lasher, MSPH, Science Policy Analyst, Stanford University
Nicholas Chartres, PhD, MHum Nutr, Associate Professor, School of Pharmacy, Faculty of Medicine & Health, The University of Sydney
Robert M. Gould, MD, President, San Francisco Bay Physicians for Social Responsibility
Rainer Lohmann, PhD, Professor of Oceanography, University of Rhode Island Graduate School of Oceanography
Rachel Morello-Frosch, PhD, MPH, Professor, UC Berkeley School of Public Health
Ted Schettler, MD, MPH, Science Director, Science and Environmental Health Network
Veena Singla, PhD, Affiliate, University of California, San Francisco
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Read full text of letter here: https://www.regulations.gov/comment/EPA-HQ-OPPT-2018-0459-0126
911 Health Watch Supports CDC Data Collection to Study 9/11 Youth Health Impact
Carter Struck
WASHINGTON, June 23 -- 911 Health Watch Inc., Albany, New York, submitted a public comment letter to the Office of Management and Budget supporting the proposed data collection by the U.S. Department of Health and Human Services Centers for Disease Control and Prevention. The organization advocates for health care and compensation for individuals affected by toxins released at the World Trade Center site following the September 11, 2001 attacks.
The letter underscores the importance of establishing a Youth Research Cohort within the World Trade Center Health Program, as mandated by Congress in
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WASHINGTON, June 23 -- 911 Health Watch Inc., Albany, New York, submitted a public comment letter to the Office of Management and Budget supporting the proposed data collection by the U.S. Department of Health and Human Services Centers for Disease Control and Prevention. The organization advocates for health care and compensation for individuals affected by toxins released at the World Trade Center site following the September 11, 2001 attacks.
The letter underscores the importance of establishing a Youth Research Cohort within the World Trade Center Health Program, as mandated by Congress in2022. This cohort targets individuals who were 21 years old or younger on 9/11, including those in utero at the time, who may have experienced exposure to airborne toxins in lower Manhattan and Western Brooklyn. The organization emphasizes that understanding resultant health conditions in this population remains a critical gap in current research.
911 Health Watch highlights that the proposed data collection represents an essential initial step towards identifying potential cohort members, enabling targeted recruitment and the development of treatment strategies for physical and mental health conditions related to World Trade Center exposure. The organization notes that the voluntary nature of the data collection minimizes respondent burden while potentially saving millions of dollars compared to active recruitment protocols.
Furthermore, 911 Health Watch stresses the significance of timely approval of this data collection to leverage public attention surrounding the 25th anniversary of 9/11, which may facilitate greater participation and cost savings. The organization praises the CDC's experience with this population and expresses confidence in the accuracy of burden estimates and methodology supporting the initiative.
By advancing this research, the World Trade Center Health Program can better address ongoing health concerns among youth exposed to 9/11 toxins and improve long-term treatment outcomes.
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Read full text of letter here: https://www.regulations.gov/comment/CDC-2026-0727-0002
323 Advocacy Organizations Urges OMB to Extend Comment Period for Grant Rule Impacting $1.2 Trillion in Funding
Carter Struck
WASHINGTON, June 23 -- A coalition of 323 advocacy organizations representing sectors in science, research, policy, and education have urged the Office of Management and Budget to extend the public comment period for its proposed revisions to Title 2 of the Code of Federal Regulations. The coalition is requesting an extension through Aug. 27, 2026, hoping a Federal Register notice will announce this adjustment by June 30, 2026.
The coalition describes the scope of the proposed regulation as broad and influential, noting that the rule would amend 91 parts of Title 2 across 456 sections, including
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WASHINGTON, June 23 -- A coalition of 323 advocacy organizations representing sectors in science, research, policy, and education have urged the Office of Management and Budget to extend the public comment period for its proposed revisions to Title 2 of the Code of Federal Regulations. The coalition is requesting an extension through Aug. 27, 2026, hoping a Federal Register notice will announce this adjustment by June 30, 2026.
The coalition describes the scope of the proposed regulation as broad and influential, noting that the rule would amend 91 parts of Title 2 across 456 sections, includingadditions and full restatements affecting government grant-making nationwide. OMB has acknowledged the proposed rule's potential effect on over $179 billion directed to small entities. The coalition highlights examples such as university research expenditures, which totaled $64 billion in fiscal year 2024 according to the National Science Foundation, and extramural funding from the National Institutes of Health amounting to approximately $36.9 billion in that year. Together, these demonstrate just part of the estimated $1.2 trillion spent by the federal government through grants and cooperative agreements, with the rule expected to impact many facets of this financial assistance.
The organizations argue that the current 45-day comment period is insufficient for the necessary multi-disciplinary analysis and meaningful input given the rule's complexity and wide-ranging implications. They point out that the rule did not appear on the Unified Agenda of regulatory actions nor prompted any meetings under Executive Order 12866 during its review phase at OMB's Office of Information and Regulatory Affairs, suggesting stakeholders have been caught off guard by the rulemaking process. The coalition underscores that thorough public engagement is fundamental to the Administrative Procedure Act, which aims to ensure agencies receive comprehensive information to enhance regulatory decisions.
Representatives of the coalition stress the value of "situated knowledge" that stakeholders bring to agency rulemaking, allowing agencies to better understand regulatory challenges, costs, and compliance likelihood. The broad membership includes organizations such as the American Association for the Advancement of Science, American Medical and Scientific Societies, various academic institutions, and many others dedicated to fostering innovation and progress across sectors like healthcare, energy, infrastructure, and education.
They cite Executive Order 12866, stressing that agencies should provide a meaningful opportunity to comment, especially given that OMB's proposed revisions represent a sweeping revision of federal financial assistance protocols. The coalition thus asserts that a 90-day comment period would better serve the public interest by enabling stakeholders to submit substantive feedback, ensuring well-informed policymaking to support grant recipients across the United States.
The extensive list of signatories reflects a cross-section of academia, healthcare, technology, environmental science, and advocacy groups that regularly interact with federal grant processes. Their collective call encourages OMB to consider the importance of broad and thoughtful public participation in finalizing this impactful regulation.
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The letter was signed by:
ACA: The Structural Science Society
Academic Pediatric Association
Academy for Radiology & Biomedical Imaging Research
Academy of Managed Care Pharmacy
Academy of Physicians in Clinical Research
AcademyHealth
Acoustical Society of America
ACRE
Acterra: Action for a Healthy Planet
ADAP Advocacy Association
Afterschool Alliance
Alliance for Academic Internal Medicine (AAIM)
Alliance for Aging Research
Alliance for Data Science and AI
Alliance for Learning Innovation (ALI)
Alliance of Nurses for Healthy Environments
Alliance to Cure Cavernous Malformation
ALS Association
American Academy of Allergy, Asthma & Immunology
American Academy of Emergency Medicine
American Academy of Hospice and Palliative Medicine
American Academy of Neurology
American Academy of Nursing
American Academy of Pediatrics
American Alliance of Museums
American Anthropological Association
American Association for Anatomy
American Association for Cancer Research
American Association for Dental, Oral, and Craniofacial Research
American Association for Public Opinion Research
American Association for State and Local History
American Association for the Advancement of Science
American Association of Colleges of Nursing
American Association of Colleges of Pharmacy (AACP)
American Association of Geographers
American Association of Immunologists
American Association of Nurse Practitioners
American Association of Physicists in Medicine
American Association of Physics Teachers
American Astronomical Society
American Brain Coalition
American Chemical Society
American College of Obstetricians & Gynecologists
American College of Physicians
American College of Radiology
American Educational Research Association
American Federation for Aging Research
American Gastroenterological Association
American Geophysical Union (AGU)
American Geriatrics Society
American Heart Association
American Industrial Hygiene Association
American Institute for Medical and Biological Engineering (AIMBE)
American Institute of Biological Sciences
American Institute of Ultrasound in Medicine (AIUM)
American Mathematical Society
American Meteorological Society
American Musicological Society
American Nurses Association
American Occupational Therapy Association
American Oil Chemists' Society (AOCS)
American Ornithological Society
American Pediatric Society (APS)
American Pharmacists Association
American Physical Society
American Physiological Society
American Phytopathological Society
American Political Science Association
American Psychological Association
American Public Gardens Association
American Society for Biochemistry and Molecular Biology
American Society for Bone and Mineral Research
American Society for Cell Biology
American Society for Clinical Investigation
American Society for Clinical Pharmacology & Therapeutics
American Society for Gravitational and Space Research
American Society for Nutrition
American Society for Pathobiology
American Society for Pharmacology and Experimental Therapeutics (ASPET)
American Society of Agronomy
American Society of Biomechanics
American Society of Civil Engineers
American Society of Health-System Pharmacists
American Society of Hematology
American Society of Nephrology
American Society of Plant Biologists
American Society of Tropical Medicine and Hygiene (ASTMH)
American Speech-Language-Hearing Association (ASHA)
American Statistical Association
American Studies Association
American Thoracic Society
American Vacuum Society (AVS)
Americans for Medical Progress
Animal Behavior Society
Arkansas Immunization Action Coalition (Immunize Arkansas)
Arthritis Foundation
ASCP - Age Friendly Pharmacists and Pharmacies
Asian American Scholar Forum
ASM
ASM International
Association for Academic Pathology (AAPath)
Association for Psychological Science
Association for Research in Vision and Ophthalmology (ARVO)
Association for Slavic, East European, and Eurasian Studies
Association for the Sciences of Limnology and Oceanography
Association for Women in Science
Association of American Cancer Institutes
Association of Art Museum Directors
Association of Biomolecular Resource Facilities (ABRF)
Association of Children's Museums
Association of Environmental Engineering and Science Professors
Association of Family Medicine Residency Directors
Association of Maternal & Child Health Programs
Association of Medical School Pediatric Department Chairs
Association of Population Centers
Association of Public Health Nurses
Association of Research Libraries
Association of Science and Technology Centers
Association of Science Museum Directors
Association of University Presses
Autoimmune Association
Big Cities Health Coalition
Biocom
Biophysical Society
Botanical Society of America
California Botanical Society
California Institute for Regenerative Medicine
California River Watch
California State University
Campaign for Tobacco-Free Kids
Campus Research Computing Consortium
Cancer Nation
Caregiver Action Network
Center for Open Science
Center on Budget and Policy Priorities
Cereals & Grains Association
Children's Cancer Cause
Children's Hospital Association
Clean Energy Business Network
Climate Psychiatry Alliance
Coalition for Academic Scientific Computation
Coastal and Estuarine Research Federation
College for Creative Studies
Computing Research Association
Concord Consortium
Conference of Boston Teaching Hospitals
Council of Medical Specialty Societies
Crohn's & Colitis Foundation
Crop Science Society of America
CSM Advising LLC
CT Public Health Association
Cure Alzheimer's Fund
Cure HHT
Cushman Foundation for Foraminiferal Research, Inc.
Dana-Farber Cancer Institute
debra of America
Defend Public Health
DefendResearch
Digital Promise Global
Ecological Society of America
EdTrust
Education Reform Now
Emory University
Endocrine Society
Entomological Society of America
EveryLife Foundation for Rare Diseases
Evidence Advocacy Center
Federation of American Scientists
Federation of American Societies for Experimental Biology (FASEB)
Federation of Associations in Behavioral and Brain Sciences (FABBS)
Fight Colorectal Cancer
Fox Chase Cancer Center -- Temple Health
Friedreich's Ataxia Research Alliance (FARA)
Genetics Society of America
Geological Society of America
George Washington University Cancer Center
German Studies Association
Gerontological Society of America
Global Health Technologies Coalition (GHTC)
GreenLatinos
HealthHIV
Heart Failure Society of America
Helminthological Society of Washington
HIV Medicine Association
Huntsman Cancer Institute
IEEE-USA
Illinois Public Health Association
Immune Deficiency Foundation
Infectious Diseases Society of America
INFORMS
Institute for Progress
International Society for Stem Cell Research
International Zebrafish Society (IZFS)
Internet2
Iowa Public Health Association
Lasker Foundation
Latino Caucus for Public Health (APHA)
Lewy Body Dementia Association
Lupus and Allied Diseases Association, Inc.
Massachusetts Public Health Alliance
Materials Research Society
Mathematical Association of America
MaxRevenue
ME/CFS San Diego
MEAction Maryland
MEAction North Carolina
MEAction, California
Minerals, Metals & Materials Society
Minnesota Public Health Association
Montana Climate and Health
NAPCRG
National Alliance for Caregiving
National Association for Biomedical Research (NABR)
National Association of City Transportation Officials
National Association of School Nurses
National Ataxia Foundation
National Consumers League
National Council of Teachers of Mathematics (NCTM)
National Council on Public History
National Education Association
National Foundation for Infectious Diseases
National Health Council
National Hispanic Health Foundation
National Humanities Alliance
National Low Income Housing Coalition
National Medical Association
National Organization for Dental Immunizers
National Postdoctoral Association
National School Boards Association
National Women's Law Center
National Women's Studies Association
Natural Resources Defense Council
Natural Science Collections Alliance
NDRI
Nebraska Cures
New America's Future of Work & Innovation Economy Program
NJME/CFS Association
North American Vascular Biology Organization
Oceanography Society
Optica, Advancing Optics and Photonics Worldwide
Organization of Biological Field Stations
Partnership for Public Service
Pediatric Nurse Practitioner House Calls
Pediatric Policy Council
Physicians for Social Responsibility
Planetary Society
Plug In America
Population Association of America
Post-Acute and Long-Term Care Medical Association
Prevent Blindness
Psychonomic Society
Pulmonary Fibrosis Foundation
reDesignED
Research!America
RetireSafe
Salem Oaks Consulting
San Diego Natural History Museum
San Jose State University
Sanford Burnham Prebys Medical Discovery Institute
Seismological Society of America
SERP Institute
Shock Society
Sigma Xi, The Scientific Research Honor Society
Social Science Research Council
Society for Advancement of Chicanos/Hispanics and Native American in Science
Society for Applied Anthropology
Society For Biomaterials
Society for Birth Defects Research and Prevention
Society for Developmental Biology
Society for Experimental Biology and Medicine
Society for Glycobiology
Society for Healthcare Epidemiology of America
Society for Industrial and Applied Mathematics
Society for Industrial Microbiology and Biotechnology
Society for Laboratory Automation and Screening
Society for Leukocyte Biology
Society for Maternal-Fetal Medicine
Society for Neuroscience
Society for Pediatric Radiology
Society for Pediatric Research (SPR)
Society for Personality and Social Psychology
Society for Range Management
Society for Research in Child Development (SRCD)
Society for the Psychological Study of Social Issues
Society for the Study of Amphibians and Reptiles
Society for the Study of Evolution
Society for Women's Health Research
Society of Behavioral Medicine
Society of Environmental Toxicology and Chemistry of North America (SETAC North America)
Society of Herbarium Curators
Society of Nuclear Medicine and Molecular Imaging
Society of Systematic Biologists
Society of Teachers of Family Medicine
Software & Information Industry Association
Soil Science Society of America
Solve M.E.
SPARC
Speculative Technologies
Spina Bifida Association
St. Jude Children's Research Hospital
Stand Up for Science
STEM Education Coalition
Study Group
T2M Advisors
TERC, Inc.
Texas Behavioral Science and Policy Institute
Third Way
TSC Alliance
UCLA
Union of Concerned Scientists
University of Colorado
University of Colorado Boulder
University of Colorado Anschutz
University of Kentucky Markey Cancer Center
University of Oregon
University of Rochester
Up for Growth Action
Vision Zero Network
West Sonoma County Alliance
Wildlife Society
Wistar Institute
Women's Health Institute
Woodley Park Institute
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Read full text of letter here: https://www.regulations.gov/comment/OMB-2026-0034-22261
