In 2022, CSRO advocacy led CMS to issue a Technical Direction Letter (TDL) (dated August 12, 2022) to its Medicare Administrative Contractors (MACs) that effectively “paused” the “down coding” of complex drug administration services. In December 2023, after repeated appeals to CMS, the substance of the TDL was published in program transmittal #R12397OTN.

Despite this program transmittal, Palmetto GBA continued to inappropriately educate practices to “down code" their complex drug administrations. After CSRO sent direct communication to Palmetto demanding action, confirmation was received that article A58527 will be retired, and this update has been displayed on the Medicare Coverage Database (MCD). CSRO is working with the MAC to revise the effective date currently listed for the retirement and will continue to provide updates as appropriate.

Please note: this communication is for informational purposes only and is not coding or billing guidance. As always, practices should code and bill items and services based on documentation in the medical record and in accordance with Medicare requirements and policy applicable to that particular item or service.

CSRO, along with a coalition of medical and healthcare organizations, met with senior CMS leadership in Baltimore to recommend reforms to the process used by Medicare Administrative Contractors (MACs) to develop coverage and payment policy in their jurisdictions. The coalition centered its recommendations on the need for meaningful interaction between the MACs and local providers on coverage and payment policy, which are discussed as part of the coalition’s Principles for Sound Local Coverage Policies.

Related, CSRO continues to press the Agency to address “down coding” and the self-administered drug (SAD) exclusion list, which have been implemented through local coverage articles, on a more permanent basis.

The Improving Seniors Timely Access to Care Act (S. 4532/H.R.8702) was reintroduced on June 12 with the endorsement of over 370 organizations, including CSRO. The legislation would establish requirements for the use of prior authorization (PA) by Medicare Advantage plans, including a requirement to use electronic PA processes meeting standards set by the Department of Health and Human Services.

In the last Congress, the bill passed the House but stalled in the Senate following an unexpected large score from the Congressional Budget Office (CBO). Since that time, however, the Centers for Medicare and Medicaid Services proposed and finalized some of the legislation’s changes to prior authorization by Medicare Advantage plans and the bill sponsors also worked with CBO to bring the score down as much as possible.

Given the overwhelming level of bipartisan support – as well as the strong showing of support from the healthcare community – this legislation is on the “short list” for enactment before the end of this Congress.

As shared in our last Bi-Weekly Update, CSRO is requesting input from the rheumatology community to gather information about home infusion services.

If you haven't already done so, please take 3 minutes to complete this brief survey by this Sunday, June 16. Thank you for your consideration.

You're Invited! Join CSRO this September 20-22 in Nashville, Tennessee, for our flagship Advocacy Conference!

Attendees will gather with fellow advocates and members of the rheumatology community to learn, network, and strategize about advocacy. Our curated program will feature sessions highlighting current issues impacting patients and practices like copay assistance, the Inflation Reduction Act, and more – click here to view the full agenda on our website.

Registration is complimentary and open to anyone currently working within or retired from the field of rheumatology. Don't miss out, register now!

Advocate alongside CSRO as we meet with Federal policymakers to highlight legislation of interest to the rheumatology community!

Rheumatologists and their practice partners are invited to log in on July 10 from 10am - 4pm ET for live conversations with health care leaders during our Virtual Advocacy Day.

Your participation amplifies the advocacy of CSRO and helps ensure that the issues impacting our patients and livelihood are heard and understood by members of Congress.

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, and click here to view a full status report of CSRO priority bills.

Be sure to check out our interactive legislative map tool for additional details.

California

Rebate Pass Through

• SB 966: Referred to committee on Health and Judiciary

Colorado

Gold Card

• HB 1149: Signed by the Governor

New Hampshire

Accumulators

• SB 354: Conference committee report not filed 

Rebate Pass Through

• SB 555: Conference committee report filed

Ohio

Biomarker Testing

• HB 608: Approved by committee 

Pennsylvania

Biomarker testing

• HB 1754: Passed the House, and approved by Senate committee

Rhode Island

White Bagging

• S2086: Passed the House, placed on Senate calendar
• H7365: Passed the House, placed on Senate calendar

Vermont

Prescription Drug Affordability Board

• S98: Signed by the Governor 

Virtual Advocacy Day: July 10, 2024

Advocate alongside CSRO as we host live conversations with health care leaders from the U.S. Senate and U.S. House of Representatives.

Business of Rheumatology: July 31, 2024

CSRO's virtual seminar series to help support rheumatology practices in building and strengthening their business.

CSRO Advocacy Conference: September 20-22, 2024

Gather with others in the rheumatology community in Nashville for CSRO's annual Advocacy Conference! 

State Society Conferences:

Find a listing of CSRO's state society member conferences on our website.

State Society Meeting Spotlight:

CSRO recently attended the Arizona United Rheumatology Alliance (AURA) meeting to connect with rheumatologists and help develop advocacy efforts in the state. In addition to the informational materials and resources located at our exhibit table, CSRO also provided an in-depth session examining issues impacting rheumatologists at both the state and federal levels. Among the issues covered were prescription drug affordability boards, non-medical switching, federal payment policy, and down-coding. CSRO was glad to connect with AURA and engage with its members!

Pictured left: AURA President Dr. Joy Schechtman and CSRO Treasurer Dr. Michael Saitta

CSRO’s state rheumatology society members host their own meetings throughout the year and CSRO appreciates the opportunity to provide a session on advocacy.

Known meetings are listed on our website – email us to add your dates or request a speaker. 

Action Center

Use CSRO's convenient online platform to easily find out who your elected officials are and engage with them directly.

Advocacy Council

Amplify your voice by assembling with other like-minded individuals to enhance CSRO’s advocacy initiatives.

Career Center

Locate the perfect fit whether you're looking for new career opportunities or trying to find the right candidate.

Explanatory Statement: “Underwater” Biosimilars

To aid in addressing the issue of "underwater" biosimilars with payers, CSRO has created a document to illustrate the extent of the problem.

Legislative Map Tool

Find your state on our interactive map tool to learn about current or proposed policy and ways you can take action to make an impact.

Payer Issues Reporting Form

Request assistance with any payer relation issues that may be impacting your patients or office.

Policy Correspondence

Easily access all of CSRO’s policy letters submitted to payers, state, and federal governments as an informational resource.

Rheum for Action

Learn about the latest advocacy issues in CSRO's advocacy column authored by Dr. Madelaine Feldman and produced in partnership with Rheumatology News.

Step Therapy Cover Sheets

Review CSRO's state-specific step therapy materials that help guide practices in gaining an exemption from step therapy protocols.

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.