SHARE:  
Regulatory Update: CMS "Pause" on Downcoding
CSRO has been working with the Center for Program Integrity (CPI) at CMS on the complex vs therapeutic coding and billing issue following our announcement on June 10, 2022, when CSRO was informed by a senior staffer at CPI that they had given “technical direction” to its Medicare Administrative Contractors (MACs) across the country to put a "pause" on the downcoding and to stop sending additional documentation requests (ADR) when physician practices submit claims for chemotherapy administration services for the following five drugs:
  • Cimzia® (J0717)
  • Orencia® (J0129)
  • Simponi Aria® (J1602)
  • Stelara® (J3358)
  • Prolia® (J0897)
 
According to CPI, their technical direction would avoid the downcoding and allow claims for the chemotherapy administration codes to be processed while CSRO gathered the needed information to justify the complex coding of the above drugs. 
 
However, CSRO has received numerous reports from practices around the country that their claims at the chemotherapy coding have been denied by their MAC.
 
CMS (CPI) had been made aware that, despite its technical direction, the MACs continue to reject claims when the complex administration codes are submitted with the five drugs. CSRO continues to engage with CMS Headquarters to resolve this issue and will provide additional information once it is known.
 
Until then, practices should bill the code they think is appropriate - If billing at the chemotherapy administration services codes and ADR letters are received, please notify CSRO at info@csro.info, as we are tracking these instances and will support practices in obtaining overrides.
Federal Update: Medicare Advantage Hearing
On Tuesday, June 28, the House Energy & Commerce Committee’s Oversight & Investigations Subcommittee held a hearing on Medicare Advantage (MA), featuring witnesses from the Office of the Inspector General, the Government Accountability Office, and the Medicare Payment Advisory Commission.
 
At a high level, the hearing examined the quality of care that Medicare beneficiaries receive through MA and the fiscal sustainability of the program. During the questioning portion of the hearing, several Members expressed concern with burdensome utilization management requirements and highlighted reform legislation related to prior authorization in Medicare Advantage.
 
Prior to the hearing, CSRO reached out to Members of the Subcommittee to provide background on some of the issues that rheumatologists encounter with MA plans. As a result, one of the Members asked a question for the record related to large volume medical record requests by MA plans, which present a severe burden on practice resources. The question asked the witnesses for steps CMS can take to prevent inappropriate diagnosis mining audits by MA plans and whether there are additional authorities the agency needs from Congress to effectively tackle this problem.
Member Exclusive: ACR Breakfast Save the Date
CSRO will be exhibiting at ACR Convergence 2022 this November 10-14!

Mark your calendar to join us on Sunday, November 13 for an exclusive state society member breakfast - more information will be shared in the coming months.
CSRO Virtual AdvocacySecond Annual Hill Day
Last week, a group of two-dozen CSRO members from 16 states across the country virtually visited Capitol Hill, connecting with 8 bipartisan Members of the U.S. House of Representatives and U.S. Senate. Members of Congress provided remarks to the group followed by live question and answer sessions. The group focused on the topics of Medicare payment policy and patient access to prescription drugs. 

Lawmakers provided updates on where various pieces of legislation that CSRO has endorsed stand, including but not limited to two utilization management reform bills: the Improving Seniors Timely Access to Care Act (S.3018/H.R.3173) and the Safe Step Act (S. 464/H.R. 2163). In addition to the lawmakers who participated, the group heard from the Executive Director of the Medicare Payment Advisory Commission (MedPAC), Dr. James Mathews.
Legislation Around the Country
What's Happening in the States
CSRO tracks legislative activity relevant to the rheumatology community and their patients. Check out the list below to see the status of CSRO priority bills from the past two weeks. For a full status report on all the bills CSRO tracks, click here.

Be sure to check out our interactive legislative map tool for additional information about current policy in your state. Plus, don't forget to add your state to your email profile here to receive state-specific updates and action alerts via email.
CALIFORNIA 
Step Therapy 
  • AB 1880: Approved by Senate Committee on Health, re-referred to Committee on Appropriations 
White Bagging 
  • SB 958: Hearing cancelled 
DELAWARE 
Accumulator Programs 
  • SB 267: House amendments adopted, passes the house, Senate concurs 
LOUISIANA 
Prior Authorization “Gold Card” 
  • SB 112: Signed by the Governor (Pharmacy services amended out of legislation) 
MASSACHUSETTS 
Step Therapy
  • H.1311: Passed the House 
PENNSYLVANIA 
Step Therapy & Prior Authorization
  • SB 225: Passes the Senate
Upcoming Events
Register Now:
Save the Date:

Find all of CSRO's event dates by visiting our Upcoming Events page, and check out past events and webinars in our Library.
Questions?
Please visit the CSRO website for other news and updates, and do not hesitate to contact us with any questions at info@csro.info.
CSRO is a 501c3 nonprofit organization dedicated to ensuring access to the highest quality care for the management of rheumatologic diseases - donate today.