Supporting Practice Sustainability
We initiate and promote congressional and regulatory advocacy that back the practice of allergy / immunology by supporting fair reimbursement, reduction of physician burden, adequate and transparent payment policies, and sustainable systems which help improve patient care. Here is what we are doing to make a difference.
• Current Medicare Reimbursement Structure Harms Patients and Providers
Medicare physician reimbursement has fallen more than 30% since 2001 when adjusting for inflation, while the costs of running a practice continually increase. We support the Provider Reimbursement Stability Act (H.R.8163). This bill would raise the budget neutrality threshold from $20 million to $54.3 million and would use increases to the Medicare Economic Index (MEI) to update the threshold every five years after. June 2026
• Community Calls on OMB to Extend Comment Period on Uniform Guidance Changes
On May 29, the Office of Management and Budget (OMB) proposed a regulation that would drastically expand political influence over the framework governing federal grants and change existing uniform guidance into binding regulation, impacting over 40 federal agencies including the NIH. OMB allowed only 45 days for public comments on this sweeping proposed regulation. The AAAAI joined over 300 other community stakeholders requesting a longer comment period. June 2026
• On June 4 and 5, 2026, the AAAAI Board of Directors met with more than 20 members of Congress and legislative staff to discuss key issues impacting our practices, patients and public health, including Medicare physician payment; utilization management/prior authorization; patient access to specialist-recommended therapies; and, penicillin allergy delabeling to improve patient outcomes, lower healthcare costs and help fight antimicrobial resistance. Find out more details shared during the visit.
• Feedback on CRUSH RFI.
In comments on a CMS’ proposed Comprehensive Regulations to Uncover Suspicious Healthcare (CRUSH), We expressed support for efforts to strengthen program integrity while raising concerns about proposals to shorten Medicare’s claims filing deadline from 365 days to 90–180 days. We noted this change could disrupt access to care by preventing physicians who are new to a practice or relocating from treating Medicare beneficiaries while their enrollment is pending. We urged CMS to rely on existing oversight tools or, at minimum, preserve billing flexibility for services furnished during enrollment review periods once enrollment is finalized. March 2026
• Medicare Part D, Medicare Advantage Policies for CY 2027.
CMS finalized updates to Medicare Advantage (MA) and Part D plans in April, 2026, including Inflation Reduction Act (IRA) implementation provisions, expanded use of risk adjustment data, and changes to Star Ratings effective January 1, 2027. While many concerns raised by the physician community were largely ignored, some Star Ratings measures supported by us will continue to be reported and publicly posted. Details can be found in the side-by-side comparison between the proposed and final rules from our expert consultants at Hart Health Strategies, Inc. April 2026
• Legislation to End Problematic PBM Kickbacks.
Pharmacy Benefit Managers (PBM) often provide referral fees or “kickbacks” to individuals or organizations that in turn shepherd their employee health plans or insurance business to that PBM. These practices undermine the integrity of the healthcare system and drive up costs. We support the PBM Kickback Prohibition Act (H.R.7895), legislation that would eliminate profit mechanisms that could distort decision making. April 2026
• Hidden Costs of Low Immunotherapy Reimbursement.
We continue to work to inform payers of the importance of patient access to allergen immunotherapy. Payer policies and practices that destabilize allergy / immunology practices threaten patient access and create barriers to care. A paper published in JACI: In Practice in December highlights the impact of these policies on public health and patient populations, and the risk of inadequate immunotherapy reimbursement. January 2026
• AAAAI Calls on CMS to Address Beneficiary Access, Provider Challenges in Medicare Advantage Proposed Rule.
We submitted comments on the CY 2027 Medicare Advantage and Part D (MAPD) proposed rule, expressing concern that several proposals could weaken plan oversight that affects patient access and continuity of care. We also opposed the removal and “downgrading” of certain Star Ratings measures related to plan complaints and appeals, urged CMS to incorporate provider experience measures addressing network adequacy and utilization management and cautioned against rescinding health equity and quality improvement requirements that help identify disparities affecting patients with allergic and immunologic diseases. January 2026
• CMS Announces Two Drug Pricing Models.
The Centers for Medicare and Medicaid Services (CMS) recently proposed two mandatory drug-pricing models, the Global Benchmark for Efficient Drug Pricing (GLOBE) Model and the Guarding U.S. Medicare Against Rising Drug Costs (GUARD) Model, targeting selected single-source Part B and Part D drugs, respectively. Under both models, manufacturers would owe additional rebates to Medicare when prices exceed international reference benchmarks. CMS estimates the GLOBE and GUARD models would reduce Medicare spending by approximately $11.9 billion and $14 billion over seven-year test periods. Medications prescribed to treat asthma and other allergy / immunology conditions are expected to be included, and we will provide feedback through the notice-and-comment process. January 2026
• AAAAI Board Members on Capitol Hill.
Members of the AAAAI Board of Directors met with key Capitol Hill offices to discuss important issues, including:
- Fixing the Medicare payment system to stabilize physician practices and protect patient access to care.
- Addressing prior authorization and step therapy practices, which delay care and hinder timely access to life-saving treatments.
- Funding the National Institutes of Health and the National Institute of Allergy and Infectious Diseases to advance research.
- Supporting the Penicillin Allergy Verification and Evaluation Act, HR 5736, the AAAAI bill to add penicillin allergy delabeling to the Medicare intake and annual wellness visits.
November 2025
• In depth comparison of the CY26 Medicare Physician Fee Schedule.
The Centers for Medicare and Medicaid Services (CMS) released its Calendar Year (CY) 2026 Medicare Physician Fee Schedule (PFS) final rule, which becomes effective beginning January 1, 2026. The rule finalizes changes to Medicare PFS payments, updates the Quality Payment Program (QPP) and Medicare Shared Savings Program (MSSP). Among several sweeping changes, the rule introduces a practice efficiency cut for many services, from which the AAAAI was able to get many allergy / immunology codes exempted. While facility fees are reduced significantly to pay for a considerably higher conversion factor, that increase combined with higher increased payment on some immunotherapy codes and the exemption of other codes from the practice efficiency cuts results in an overall estimated gain of 7% for allergy / immunology.
CMS finalized the following two conversion factors (CFs) for 2026:
- $33.5675 for items and services furnished by Qualifying APM Participants, which reflects a 3.77 percent increase relative to the 2025 CF
- $33.4009 for other items and services, which reflects a 3.26 percent increase relative to the 2025 CF
Given the length of the rule, Hart Health has divided their side-by-side comparison into three separate documents:
- A summary of payment and other policy provisions
- A summary of provisions related to the QPP, MSSP and Medicare Diabetes Prevention Program (MDPP)
- A summary of provisions related to the newly established ASM
November 2025
• CY26 Medicare Physician Fee Schedule.
On Friday, October 31, the Centers for Medicare and Medicaid Services (CMS) released the CY 2026 Medicare Physician Fee Schedule (PFS) Final Rule, incorporating several recommendations the Academy made in its September 2025 comment letter. View a summary of the fee schedule, courtesy of our parters at Hart Health Strategies. October 2025
• Telehealth access for Medicare patients and other government shutdown disruptions to practice and research.
The U.S. Government shutdown on October 1 after Congress failed to pass the 12 appropriations bills, which would allow the departments covered under those budgets to operate or continue funding for 2026. While Medicare benefits generally continue uninterrupted, certain rules tied to annual appropriations cycles are no longer in effect. The AAAAI notified members to reschedule telehealth appointments for Medicare patients before October 1 or plan accordingly. Disruption to agency activities impacting clinical care include discontinuation of graduate and post-doc training and basic and translational research at the NIH and ongoing work to finalize the Physician Fee Schedule for 2026. October 2025
• Cigna’s automatic downcoding of E/M visits delays care, creates barriers.
Cigna published a new Evaluation and Management (E/M) Coding and Accuracy policy (R49), which alone downcodes evaluation and management (E/M) office visits. We issued a response to this policy, stressing that it reduces patient access to care, delays patient care, increases administrative burdens to physicians and erodes trust between payers and providers. September 2025
• Physician reimbursement policy changes and response.
The Centers for Medicare and Medicaid Services (CMS) proposed CY2026 Medicare Physician Fee Schedule (PFS) has many changes. It prioritizes community-based practice by moving away from facility fees to increase the conversion factor. The proposed increased payment rates for allergen immunotherapy codes are good news for allergist / immunologists. However, the proposal does not mention ongoing physician reimbursement policies that do not adjust for inflation or other practice expense-related increases. Quality payment program proposals freezing reporting thresholds were welcome, while the need for an allergy / immunology-focused MIPS Value Pathway (MVP) looms. We submitted comments asking that reimbursement rates be tied to the Medicare Economic Index and addressed issues in practice expense survey data that would have significantly reduced allergy / immunology reimbursement rates.
We also submitted a letter of support for CMS’ proposal to pay off-campus provider based departments the same rate as physician offices for providing drugs and called for greater 340B program transparency. September 2025
• AAAAI and others raise concern on quality measures policies.
We joined other American Medical Association (AMA) Federation members asking Administrator Mehmet Oz to address ongoing frustrations with CMS’s process for reviewing and selecting quality measures. We called for a robust portfolio of quality measures that enable quality improvement and promote accountability. September 2025
• Pharmacists’ proposed scope of practice concerns.
The Ensuring Community Access to Pharmacist Services (ECAPS) Act (H.R. 3164 / S. 2426) aims to expand Medicare coverage of pharmacist-administered tests for common respiratory illnesses to allow pharmacists to prescribe treatments for those conditions. We continue to have concern about nonphysician health specialists performing tasks that should be handled by physicians. August 2025
• Step therapy in Medicare Advantage hinders patient access.
We joined more than 50 other medical societies in writing to the Office of Inspector General (OIG) asking them to review the impact of access to medically necessary care from Medicare Advantage (MA) plans’ use of step therapy for Part B drugs. The letter shows examples of misuse of MA Part B drug step therapy requirements and concerns for rural patients and explores how the process interferes with physician-patient relationships. This included an example of off-label use of immunosuppressive drugs in children with severe atopic dermatitis. August 2025
6/30/2026