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We, the undersigned, write to you regarding the proposed implementation of the WISeR (Wasteful and Inappropriate Service Reduction) model released by the Center for Medicare and Medicaid Innovation (CMMI) on June 27, 2025. We urge you to support H.Res.704, which opposes the WISeR model and its potential harm to patients. Furthermore, we strongly encourage you to support a Department of Labor/Health and Human Services budget that disallows the use of funds to implement the WISeR model.
The WISeR model claims to reduce “wasteful” use of services via prior authorization, a process through which medical services are vetted to determine insurance coverage eligibility. Specifically, WISeR promises to use artificial intelligence (AI) to perform prior authorizations. Prior authorizations are not a cost saving measure; rather, the American Medical Association reports that when prior authorization is involved in care, more resources are utilized and more visits are performed, creating unnecessary expenditures. The use of AI would only compound this, as detailed in a 2024 Senate Committee Report which found that, when AI is used for prior authorization, the rate of denial is 16 times higher than that of private insurance-employed clinicians.
Furthermore, the WISeR model represents an attempt to utilize prior authorizations in the manner employed by private insurance companies administering Medicare Advantage. Medicare Advantage (MA) is a privatization of traditional Medicare that makes billions of dollars by denying and delaying care. Prior authorizations are key to this strategy, and the WISeR model financially incentivizes the denial of care by rewarding AI companies for each denial. Previous usages of AI-driven prior authorizations have repeatedly failed. Recently, a lawsuit against United Healthcare insurance found that AI was unfairly used to deny claims and delay care, with AI-determined prior authorizations demonstrating a 90% error rate. This does not reduce wasteful spending; instead, it burdens patients with unnecessary cost of care. Rather than perpetuate prior authorizations, we must target the corporations that profit at the expense of our most vulnerable populations. It is clear that the use of AI to perform prior authorizations is subject to fraud and lends itself to inefficient, expensive care that benefits corporations, not patients.
The role of the physician is to provide appropriate treatment options for the patient in front of them. We implore you to recognize that there is no role for third-party AI algorithms in providing care. Let providers provide care!
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