The comment period for the proposed 2027 Medicare Physician Fee Schedule closed Sept. 14, and ACAAI made sure the voice of allergy was heard. In the proposed rule, CMS specifically requested feedback on CPT code 95165 as it considers requests from a stakeholder group led by the College’s Advocacy Council to update Medicare’s coverage policy for this code. One of our highest priorities was Medicare’s outdated definition of a “dose” for CPT code 95165. CMS currently defines a billable dose as a 1 cc aliquot, rather than using the CPT definition that reflects how allergen immunotherapy is actually prepared and administered. ACAAI urged CMS to adopt the CPT definition of a dose as a single injection from a multidose vial and to modernize related utilization policies.
ACAAI submitted comprehensive comments
The Advocacy Council submitted formal comments to CMS explaining why the current policy does not reflect contemporary allergy practice. We emphasized the clinical realities of individualized immunotherapy, the administrative burden created by having Medicare use a definition different from CPT, and the potential impact on patient access. We also addressed the 30-unit Medically Unlikely Edit (MUE) for CPT 95165 and recommended a more clinically appropriate approach to utilization limits.
Allergists made their voices heard
ACAAI also asked individual allergists to submit their own comments to CMS and provided members with a sample letter to make participation as easy as possible. Members were encouraged to personalize their comments with examples from their own practices and explain how Medicare’s policy affects physicians and patients.
Thank you to every ACAAI member who took the time to submit a comment. Individual physician voices matter. By participating, our members reinforced that this is not simply an organizational concern — it is a real problem encountered by practicing allergists across the country.
ACAAI led a broad coalition
We knew that CMS also needed to hear from organizations beyond ACAAI. The College therefore organized and led a national coalition letter supporting modernization of the CPT 95165 dose definition. More than 30 organizations ultimately joined the effort, including national medical organizations, patient advocacy organizations, and state and regional allergy societies.
The breadth of the coalition was important. It demonstrated that modernizing this policy is not simply about physician reimbursement. It is about reducing unnecessary administrative complexity, promoting consistent policies across payers, and preserving patient access to allergen immunotherapy.
We are grateful to all of the organizations that joined ACAAI in this effort.
Taking the message to Congress
Our advocacy did not stop with comments to CMS. ACAAI worked closely with Representative Bob Onder, MD, who took the lead on a congressional letter to CMS supporting modernization of the 95165 policy. We also worked to build support among other members of Congress and the Doctors Caucus, adding an important congressional voice to the physicians, patients, and medical organizations asking CMS to act.
Congressional engagement reinforces an important message: Medicare policies should support clinically appropriate care rather than create unnecessary administrative barriers that can discourage physicians from treating Medicare beneficiaries.
What happens next?
The Sept. 14 deadline marked the end of the comment period, but not the end of Advocacy Council’s work. CMS will now review the comments and determine what changes, if any, to include in the final 2027 Medicare Physician Fee Schedule.
Later this month, the Advocacy Council Strike Force will travel to Capitol Hill to continue advocating for modernization of the CPT 95165 policy. The group will also advocate for Congressman Bob Onder, MD’s Allergy and Asthma Patient Protection Act, another important ACAAI priority aimed at addressing insurance barriers that interfere with patient care.
ACAAI will remain engaged with both CMS and Congress as these efforts move forward. We cannot predict what CMS will ultimately decide, but we have made the strongest case possible: formal ACAAI comments, individual allergists’ comments, a broad national coalition, congressional support, and direct advocacy on Capitol Hill.
The Advocacy Council – ADVOCATING FOR ALLERGISTS AND THEIR PATIENTS.
