The Green Mountain Care Board has done legislative reports and collects reporting on prior authorization. Additionally, GMCB convenes the Primary Care Advisory Group which has developed prior authorization proposals which were presented to GMCB in 2018. Prior authorization means the process used by a health plan to determine the medical necessity, medical appropriateness, or both, of otherwise covered drugs, medical procedures, medical tests, and health care services. The term “prior authorization” includes preadmission review, pretreatment review, and utilization review (18 V.S.A. § 9418(15)).

GMCB Legislative Reports on Prior Authorization

Below are links to legislative reports by GMCB on prior authorization. 

• Act 183 of 2022: 
  • Prior Authorizations; Administrative Cost Reduction Report by Department of Financial Regulation (DFR) in collaboration with GMCB
  • PPT Presentation: Act 183 Report (4/26/2023)
• Act 140 of 2020: 
  • Act 140 of 2020, Sec. 10: Opportunities for and Obstacles to Aligning and Reducing Prior Authorizations under the All-Payer ACO Model (Submitted 1/14/2022)

Prior Authorization Reporting from Health Insurance Carriers

Insurer Prior Authorization Review Attestations

Under 18 V.S.A. § 9418b(h)(2), a health plans shall attest to DFR and GMCB annually on or before September 15 that it has completed the review and appropriate elimination of prior authorization requirements as required by 18 V.S.A. § 9418b(h)(1). 

2024

• BCBSVT Annual Report
  • BCBSVT Attestation
• Cigna Annual Report (below are Exhibit 3 documents)
  • PS-6 Measuring Accessibility of Medical Service
  • PS-8 Measuring Availability of Practitioners and Providers
  • UM-20 Network Adequacy Provision (NAP)
• MVP Health Annual Report

2023

• 2023 Attestation Form: As proposed in the Act 183 report on Prior Authorization, GMCB and DFR have developed an attestation form with questions about how the health plan reviews and modifies prior authorization requirements. 
  • BCBSVT Attestation Response (9/11/2023)
    • Added/Removed PAs (12/05/2023)
    • Follow Up Questions (1/17/2024)
  • Cigna Attestation Response (9/13/2023)
    • Added/Removed PAs (9/13/2023)
    • Most Requested PAs (9/13/2023)
  • MVP Attestation Response (9/15/2023, updated 1/15/2023)
  • Wellfleet Attestation Response (9/14/2023)

2022

• 2022 Attestation Letters
  • BCBSVT 2022 Attestation Letter
  • MVP 2022 Attestation Letter
  • Cigna 2022 Attestation Letter
  • Wellfleet 2022 Attestation Letter

Gold Carding Pilot Program Reports

Act 140 of 2020, Section 11: Implementation of pilot program to exempt or streamline prior authorization requirements with a report due on or before January 15, 2023.

• Wellfleet Insurance (01/15/2023)
• Cigna Health and Life Insurance Company (01/15/2023)
• BlueCross BlueShield Vermont (01/15/2023)
• MVP Health (01/13/2023)

Other Reporting on Prior Authorization

• The Department of Financial Regulation collects  Health Insurers Annual Reports which include information about utilization review. Those reports can be found here.