Prior authorization has been a recent target of legislative activity to increase patient access. One method of reducing prior authorization is “gold carding”, but states have also pursued a handful of other tools.

Prior Authorization Reform Trends in 2025

Gold Card Programs Lead Prior Authorization Reform

Gold carding instructs insurers to allow providers who have a high (80%-90%) prior authorization approval rate to bypass prior authorization for up to a year for those prescriptions or services they routinely get approved for. Arkansas, Colorado, Louisiana, Texas, West Virginia and Wyoming have all adopted gold carding legislation prior to this past legislative session. In 2025, Arkansas, Texas and West Virginia amended their existing gold card programs. 

Other Ways to Increase Patient Access

Another path to increase patient access is removing prior authorization or step therapy altogether for specific classes of prescription drugs or procedures. This is most commonly seen with drugs prescribed for mental health or cancer. Similarly, there was a trend to extend prior authorization granted by one insurer to an enrollee’s new policy for a specified amount of time, generally 3 months to a year. Also, requiring insurers to make determinations within 24 hours for urgent requests or 48 hours for non-urgent requests.

Artificial Intelligence Restrictions Emerge as New Focus

Lastly, a handful of bills prohibited the use of AI in prior authorizations, or to require confirmation of adverse prior authorization decisions from a human medical professional, and to provide transparency for denials.

Notable Prior Authorization Enacted Legislation in 2025

Below are a few notable bills that addressed prior authorization during the 2025 state legislative sessions.

• Arkansas: HB 1301 amends the state’s gold card program to remove the existing allowance for  insurers to withdraw gold card status from a healthcare provider if that provider increases the number of gold carded procedures by 25%. It also extends the gold card privilege to the provider’s group practice.
• Iowa: HF 303 requires utilization review organizations to provide decisions within specific timeframes, for, urgent requests within 48 hours of receipt and for non-urgent requests within 10 calendar days. It also requires utilization review organizations to submit annual reports to the Insurance Commissioner, including the data on approval/denial rates for both urgent and non-urgent requests. The bill originally included a gold card pilot program, but that was removed at the last minute.
• Indiana: SB 480 establishes timeframes for review of prior authorizations. Urgent requests must be reviewed within 24 hours and non-urgent requests must be reviewed within 48 hours. It also requires a utilization review entity to honor an authorization that was granted to a covered individual by a previous utilization review entity for at least the initial 90 days of the covered individual's coverage under a new health plan.
• Maryland: HB 820 mandates that insurers using artificial intelligence for utilization review do not allow the use of group datasets for decision making, but patient-specific information. The insurer must also report to the Insurance Commissioner if artificial intelligence was used in any adverse determinations.
• Montana: HB 398 requires that when a person switches health plans, the new plan must honor prior approvals for healthcare services for at least three months. It further establishes that only licensed physicians can issue adverse determinations. The bill also makes prior authorization approvals valid for 12 months for enrollees diagnosed with chronic conditions. 
• New Mexico: HB 39 removes prior authorization and step therapy for enrollees diagnosed with rare disease. It includes off-label prescribing in that exception, if the medication is being used for the treatment of a rare disease.
• Texas: HB 3812 extends the gold card look-back period from 6 months to one year. 
• West Virginia: SB 833 removes the prescribing of medication from the gold card program.

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