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The Second Wave of UnitedHealthcare's Prior Authorization Cuts Started in November

Client Alert

In August 2023, UnitedHealthcare released its plan to eliminate roughly one-fifth of its then-current prior authorization requirements. The first round of prior authorization cuts took effect on September 1, 2023. In that round, UnitedHealthcare eliminated the necessity for some prior authorizations for UnitedHealthcare Medicare Advantage, UnitedHealthcare commercial, UnitedHealthcare Oxford and UnitedHealthcare Individual Exchange plan members. The second and final round of prior authorization cuts began on November 1, 2023. The November 2023 Prior Authorization Cuts apply to the same plans as well as community plans (i.e., Medicaid managed care plans).

UnitedHealthcare’s Prior Authorization Cuts

The prior authorization cuts are part of UnitedHealthcare’s comprehensive effort to simplify the healthcare experience for members and providers. In sum, the cuts account for nearly 20% of UnitedHealthcare’s overall prior authorization volume.

The prior authorization process requires a patient to obtain approval from their health plan before proceeding with a medical service. The process results in barriers to timely care for patients, and is expensive, inefficient, and administratively burdensome for providers. Payers claim that providers do not always make appropriate, high-value healthcare decisions for their patients.

Starting November 1, 2023, some prior authorization codes procedures in cardiology, genetic testing, hysterectomy, spine surgery, radiology, arthroplasty, vein procedures and site of service sterilization were removed. Examples include:

  • Spine surgery codes 22864 (removal disc arthroplasty anterior 1 interspace cervical), 22865 (removal disc arthroplasty anterior 1 interspace lumbar), and 0095T (removal total disc arthroscopy anterior approach, each additional interspace, cervical); and
  • Cardiology codes 93303 (complete transthoracic echocardiography for congenital cardiac anomalies), 93304 (transthoracic echocardiography for congenital cardiac anomalies; follow-up or limited study), and 93306 (performing and interpreting of a complete transthoracic echocardiogram). 

Prior Authorization Cuts Are Becoming a Trend

UnitedHealthcare is not the only payer that has announced prior authorization cuts this year. In August 2023, Cigna Healthcare removed roughly 25% of medical services from prior authorization requirements. This cut encompassed more than 600 codes, including roughly 100 surgical codes and 200 genetic testing codes, in addition to codes for durable medical equipment, prosthetics, and other services. Additionally, in September 2023, Blue Cross Blue Shield of Michigan announced that it was cutting approximately 20% of its prior authorization requirements and expanding its gold card program, which adjusts prior authorization requirements for providers with a track record of high-quality care and a high approval rating over six months or more.

In 2024, United Healthcare plans to implement a national gold card program for provider groups that meet eligibility requirements. Instead of adhering to the prior authorization process, qualifying providers in the program will follow a simplified notification process. UnitedHealthcare is set to publish informational guidance on this program before the end of the year.

If you have questions about the prior authorization process or UnitedHealthcare's prior authorization cuts, please contact your local BMD Healthcare Attorneys Daphne Kackloudis at dlkackloudis@bmdllc.com or Jordan Burdick at jaburdick@bmdllc.com.


Ohio House Bill 537: Proposed Regulations for Midwives and Birthing Centers

House Bill 537, introduced in the Ohio House of Representatives, proposes a comprehensive regulatory framework for certified nurse-midwives, certified midwives, licensed midwives, and traditional midwives. The legislation would clarify scope of practice, establish licensure standards, and impose new requirements for freestanding birthing centers and home births. Healthcare providers and facilities should be aware of the proposed changes and their potential operational impact.

Proposed Health Information Privacy Reform Act Expands Protections Beyond HIPAA

The Health Information Privacy Reform Act (HIPRA) seeks to extend privacy protections to health data not covered under HIPAA, including data collected by apps and wearables. HIPRA introduces broader definitions of protected health information, strengthens privacy and security requirements, establishes patient notification rights, and sets national de-identification standards. Companies processing health data should monitor developments to ensure compliance.

Medicare Updates on Skin Substitutes: LCDs Withdrawn, Payment Changes Take Effect

Medicare’s planned Final Local Coverage Determinations (LCDs) for skin substitutes were withdrawn in late December 2025, meaning previous coverage rules remain in effect. The 2026 Medicare Physician Fee Schedule introduces a single payment rate of approximately $127.14 for these products. Providers should review implications for diabetic foot and venous leg ulcer treatments.

Understanding the Seven Core Elements of an Effective Healthcare Compliance Program

The Affordable Care Act requires healthcare providers participating in Medicare, Medicaid, and CHIP to maintain an effective compliance program. Guidance from the Department of Health and Human Services and the Office of Inspector General outlines seven core elements that form the foundation of these programs, from written policies and compliance oversight to auditing, training, and corrective action. This alert highlights each element and explains how practices can tailor compliance programs to their size and risk profile while meeting federal expectations.

Preventing a Board Investigation

Healthcare professionals in Ohio are subject to licensing board investigations that can lead to disciplinary action. Staying compliant with regulations, documenting carefully, and operating within your professional scope can help prevent issues. If contacted by a board, working with an attorney is critical to protect your license and rights.