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Physician Feedback Needed in Response to NEW Prior Authorization Process

Your feedback is needed on an important new law backed by the Arizona Medical Association (ArMA) — the Arizona Department of Insurance and Financial Institutions (DIFI) will be approving two standardized “prior authorization” forms in response to the implementation of HB2621, an ArMA priority bill passed in the 2021 legislative session. Per HB2621 requirements, the two standardized forms will need to be adopted for use starting on Jan. 1, 2023.

In order to approve the two standardized forms, the Director of DIFI has reached out to ArMA seeking stakeholder input from the physician community. Below you can find links for each of the two draft prior authorization forms, background information and how to submit feedback.

Draft 1, click here.

Draft 2, click here.

After reviewing the draft forms, please provide any feedback you may have directly to DIFI by emailing Feedback must be submitted on or before Oct. 29, 2021.

Background on the Draft Forms Development

The bill requires that the prior authorization forms must:

  1. Not exceed two printed pages. This two-page limit does not apply to or include a provider’s notes or documentation that the provider submits in support of a prior authorization request.
  2. Meet the electronic submission and acceptance requirements prescribed in section 20-3403.

After a comprehensive review, DIFI identified the following two states’ forms that:

  1. Have been in use for several years;
  2. Involved extensive and varied stakeholder engagement in the development process; and
  3. Meet the requirements of Arizona law.

The following is background on both the Texas and Massachusetts state forms:

Texas — Texas Insurance Code Chapter 1217 required the commissioner to prescribe prior authorization forms with input from an advisory committee. The rule prescribing the standard forms was adopted December 1, 2014, and insurers were required to accept the forms beginning September 1, 2015. No changes have been made to the form since that time. Their advisory committee, composed of equal numbers of members representing physicians, non-physician providers, hospitals, health benefit plans, and the Texas Health and Human Services Commission, met in three in-person sessions to provide input on the form’s content. The Texas form meets the two-page requirement, contains all the necessary elements, and is EMR compatible.

Massachusetts — The Massachusetts forms have been in use since November 2015. The form is streamlined at one and a half pages and contains all the necessary elements. Massachusetts utilized an organization called the Massachusetts Collaborative to develop its prior authorization forms. The Collaborative, established in 2005, is made up of providers, hospital administrators, and insurers. The form meets the two-page requirement, contains all the necessary elements, and is EMR compatible.

Both forms above are based predominantly on the Texas forms with nominal elements of a Massachusetts form. The forms endeavor to ease administrative burden while still collecting necessary pharmacological information, including information necessary to alert dangerous medication interactions or those medications that are potentially addictive.

Submitting Feedback — DEADLINE

Your feedback is important. It may be sent directly to DIFI by emailing on or before October 29, 2021. If you have any questions related to ArMA’s position on this bill or our lobbying efforts, please e-mail Jon Amores at

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