MedicaidPrior AuthMedium impact
Hepatitis C Virus (HCV) Retrospective Review Process
Maryland Medicaid·MD · Infectious Disease, Internal Medicine, Gastroenterology·Provider Transmittal
Effective date
Dec 3, 2021
We identified it
Jun 20, 2026
Summary
Maryland's Medicaid managed care organizations (MCOs) must now review and approve all Hepatitis C virus (HCV) medication prior authorization requests independently without Department approval, then undergo monthly retrospective reviews for compliance with established clinical criteria. Non-compliance with clinical criteria 100% of the time will result in sanctions. This policy establishes specific treatment protocols by HCV genotype, cirrhosis status, and treatment history, with mandatory pre-treatment evaluations and contraception requirements for ribavirin-containing regimens.
Action Required
REQUIREMENTS:
- Effective immediately (December 3, 2021): Billing and clinical teams must ensure all HCV prior authorization requests submitted to MCOs include complete documentation per the clinical criteria in Attachment A, including: chronic HCV diagnosis with genotype/sub-genotype, HCV RNA quantitative (within 180 days for non-cirrhotic; within 90 days for cirrhotic patients), fibrosis test results, prior treatment history, HIV/HBV status with viral suppression data (within 6 months), and adherence assessment.
- By first submission: Providers must reference the genotype-specific treatment tables (Treatment Naïve or Treatment Experienced by prior regimen type) to ensure prescribed HCV medications align with approved therapy duration and regimen by cirrhosis status (None/Compensated/Decompensated).
- Before each HCV prior authorization submission: Confirm ribavirin-containing regimens include documented dual contraception plan for patients/partners of childbearing age throughout therapy plus 6 months post-treatment.
- Ongoing: Coordinate with MCOs to understand their retroactive review findings; any MCO sanctions for non-compliance may affect payment for previously approved claims. Track all HCV approvals for audit purposes to demonstrate 100% compliance with clinical criteria.
- Responsible parties: Providers (treatment plan development and documentation), Billing team (prior auth submissions with complete documentation), Pharmacy (verify medication selection matches criteria tables).
- Consequence: MCO sanctions for <100% compliance with HCV Clinical Criteria; claim denials if documentation is incomplete or therapy selection deviates from approved protocols.