June 24, 2025

Attached please find a very useful resource document re: nonprofits and lobbying from the Lawyers Alliance.

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With the help of your advocacy (thank you!) the NYS bill to help with nonprofits’ NYS contracts – S7001/A7616 – passed the NYS Senate and Assembly! Next week we will be back to you with requests for advocacy to compel Gov. Hochul to sign the bill into law immediately!

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Attached please find what I view to be a helpful resource for agencies serving immigrant families.  It starts with House reconciliation bill provisions that touch immigrant families however it was recently updated to include information regarding how the current Senate draft Reconciliation bill language treats these critical provisions proposed by the House (in red as of 6/16)

The document is from Protecting Immigrant Families (PIF) – a national advocacy group that was part of a line up of speakers providing information to advocates from across the country today during the FamiliesUSA Big Tent Advocacy call we told you about yesterday where we heard from 3 key senior health policy advisors working for the Senate Finance Committee’s ranking minority member, Senator Wyden (Dem) of Oregon.
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The Fox Guards the Hen House – Translating AHIP’s Commitments to Streamlining Prior Authorization

Health insurers delayed mandatory reforms, then rebranded them as voluntary pledges

“We urge the Administration to consider the timing of these policies in the context of the broader scope of requirements and challenges facing the industry that require significant system changes.”

• AHIP, March 13, 2023 (in a letter to CMS Administrator Chiquita Brooks-LaSure responding to CMS’s proposed rule on Advancing Interoperability and Improving Prior Authorization Processes, proposed Final Rule, CMS-0057-P)

“Health insurance plans today announced a series of commitments to streamline, simplify and reduce prior authorization – a critical safeguard to ensure their members’ care is safe, effective, evidence-based and affordable.”

• AHIP, June 23, 2025 (press release announcing voluntary prior authorization reforms)

What a difference two years make.

After lobbying aggressively to delay implementation of the PA reforms proposed by the previous administration (successfully delayed one year and counting), AHIP, the big PR and lobbying group for health insurers, now claims the mantle of reformer, announcing a set of voluntary commitments to streamline prior authorization.

So naturally, the industry’s “commitments” deserve closer scrutiny. Let’s unpack them. As a former health insurance industry executive, I speak their language, so allow me to translate. AHIP, which has no enforcement power, by the way, claims that 48 large insurers will:

1. Develop and implement standards for electronic prior authorization using Fast Healthcare Interoperability Resources Application Programming Interfaces (FHIR APIs).Translation: CMS is already requiring all insurers to do this by 2027. We might as well take credit preemptively.
2. Reduce the volume of in-network medical authorizations.Translation: We already demand hundreds of millions of unnecessary prior authorizations for thousands of procedures and services, so cutting a few (who knows how many?) should be a layup and won’t cut into profits.
3. Enhance continuity of care when patients change health plans by honoring a PA decision for a 90-day transition period starting in 2026.Translation: We’re already required to do this in Medicare Advantage. And since we delayed implementation of e-authorization until 2027, we’re in the clear until then anyway.
4. Improve communications by providing members with clear explanations for authorization determinations and support for appeals.Translation: We’re already required by state and federal law to do this. We’ll double-check our materials.
5. Ensure 80% of prior authorizations are processed in real time and expand new API standards to all lines of business.Translation: We had to promise to hold ourselves accountable to at least one measurable goal. We will set the denominator – we’ll decide which procedures and medications require PA – so we’ll hit this goal, no problem, and we might even use more non-human AI algorithms to do it.
6. 6. Ensuring medical review of non-approved requests.Translation: People will be relieved we’re not using robots. And we’ll avoid having Congress insist that reviews must be done by a same-specialty physician, as proposed in the Reducing Medically Unnecessary Delays in Care Act of 2025 (H.R. 2433).

Of course, I wasn’t in the room when AHIP drafted these commitments, so take my translations with a grain of salt. But let’s be honest: These promises are thin on specifics, short on accountability, and devoid of measurable impact.

They also follow a familiar script, blaming physicians for cost escalation by “deviating from evidence-based care” and the “latest research”, while positioning PA as a necessary safeguard to protect patients from “unsafe or inappropriate care.” And largely ignoring how PA routinely delays necessary treatment and harms patients.

It’s also rich coming from an industry still reliant on something called the X12 transaction standard – technology that is now over 40 years old – to process prior authorization requests, while simultaneously pointing the finger at providers for outdated technology and being slow to adopt modern systems. Many insurers did not start accepting electronic submissions of prior authorization until roughly 2019, nearly 20 years after clinicians started using online portals such as MyChart in their regular practice. The claim that providers are the ones behind on technology is another ploy by insurers to dodge scrutiny for their schemes.

We shouldn’t settle for incremental fixes when the system itself is the problem. Nor should we allow the industry that created this problem – and perpetuates it in its own self-interest – to dictate the pace or terms of reforming it.

As we argued in our recent piece, Congress should act to significantly curtail the use of prior authorization, limiting it to a narrow, evidence-based set of high-risk use cases. Insurers should also be required to rapidly adopt smarter, lower-friction cost-control methods, like gold-carding trusted clinicians (if it can be implemented with integrity and fairness), without compromising patient access or clinical autonomy.

Letting the fox design the hen house’s security perimeter won’t protect the hens. It’s time for Congress to build a better fence.

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Medicaid work requirements and behavioral health: 5 notes

Becker’s, 6/24

Proposed Medicaid work requirements include some exceptions for individuals with mental health conditions and substance use disorders, but questions remain about how these exceptions would be implemented, according to a June 23 report from KFF. 

In May, the House passed the “One Big Beautiful Bill,” a sweeping budget reconciliation package. The legislation includes nearly $800 million in cuts to Medicaid funding over 10 years. 

The bill would implement requirements for able-bodied Medicaid beneficiaries 19 and older to complete 80 hours of work or other qualifying activities per month to receive benefits. The bill includes exemptions from work requirements for those with “disabling” mental disorders, and substance use disorders. 

Here are five things to know: 

1. ACA expansion is the primary pathway to Medicaid eligibility for individuals with mental health and substance use disorders. Among Medicaid-covered adults with substance use disorder or opioid use disorder, 6 in 10 are eligible for Medicaid on the basis of income. 
2. The version of the bill passed by the House does not define which diagnoses constitute disabling mental disorders. 
3. Common behavioral health symptoms, including challenges with concentration, anxiety and difficulties managing stress, could make it more difficult for some individuals to report their work or exemption status. 
4. Mild and moderate mental health disorders can lead individuals to have gaps in employment, but these conditions may not qualify Medicaid beneficiaries for exemptions from the work requirement. 
5. Individuals with new or undiagnosed behavioral health conditions may struggle to maintain their Medicaid coverage without an official diagnosis. 

In May, Chris Hunter, CEO of Franklin, Tenn.-based Acadia Healthcare, said he is optimistic work requirements will not affect most of the inpatient behavioral health providers’ patients. 

“We continue to believe the patient populations that we serve, including some of the highest-acuity mental health issues in the country, are going to be relatively less impacted in terms of the risk of losing Medicaid access,” Mr. Hunter said. 

Read KFF’s full report here.