Comment:

AMA strongly believes that reviews should be limited to outlier physicians and only collect the minimally necessary amount of data to assist in payment, billing, and narrowly defined "health care operations". Furthermore, "medical necessity" is defined by the AMA HOD as: Health care services or products that a prudent physician would provide to a patient for the purpose of preventing, diagnosing or treating an illness, injury, disease or its symptoms in a manner that is: (a) in accordance with generally accepted standards of medical practice; (b) clinically appropriate in terms of type, frequency, extent, site, and duration; and (c) not primarily for the economic benefit of the health plans and purchasers or for the convenience of the patient, treating physician, or other health care provider.

Summary:

This use case needs to be narrowed in order to prevent medical necessity determinations delaying or completely impeding access to appropriate care.