Act 111 Prior Authorization Reform

The law went into effect in 2025, and it applies to commercial health plans regulated by the State (such as BCBSVT and MVP plans sold on the exchange and the Vermont State Employees Health Plan), not Medicaid, Medicare, or large group health plans.

What Act 111 does:

1. Allows primary care providers to order tests, imaging, and procedures with no prior authorization
2. Honors prior approvals for 5 years for ongoing medications and 1 year for all other medications
3. Implements exemptions to “step therapy” or “fail first” policies, which require a patient to try and fail one or more medications before they can access the medication recommended and prescribed by their healthcare provider.
4. Makes at least one asthma controller medication readily available without prior authorization
5. Allows patients to continue on a stable medication or treatment for at least 90 days after switching health plans
6. Requires health plans to respond to urgent prior authorization requests within 24 hours

• Read the text of the law here.
• Find a summary of the law here.
• Read the Vermont Department of Financial Regulation FAQ document here
• 2024 Vermont Clinician & Administrator PA Survey
• Read the Governor's letter when he signed the bill here.
• Read the VMS press statement on the Governor signing the bill here.
• Read the Vermont Department of Financial Regulation FAQ document here.
• Read a fact sheet about these important “step therapy” reforms here.
• See available resources from the American College of Radiology to assist with clinical decision-making regarding imaging in the absence of PA