The College’s Advocacy Council works diligently to monitor government and regulatory issues affecting allergists, their practices and their patients. The Advocacy Council Board, led by Chairman J. Wesley Sublett, MD, MPH, FACAAI, works together tirelessly to advocate for our specialty on a variety of issues.
Over the last 10 years, the College has invested heavily on reimagining, and subsequently restructuring, the advocacy/House of Delegates aspect of our mission. Our leadership, committee members, and volunteers have spent thousands of hours building layers, bridges, teams, and programs to advocate and support you, the practicing allergist. We are always looking for considerate, collaborative, engaged members to help with our efforts.
Advocacy can look very different depending on the topic, the people involved, and whether it is a local, state, or national issue. Advocating also looks different; advocacy can happen in person, via email, telephone, and even social media. Get involved – find what works best for you, an issue you are passionate about, and advocate! If you feel that it’s time for you to help advocate for all allergists, we are ready to help you make it happen!
The College’s Advocacy Council is keenly aware of pain points in allergists’ practices and works on the national, state and local levels to address them. Below are recent actions:
- College leaders worked jointly with AAAAI and AAO to develop “Guidance for the evaluation by payors of claims submitted using Current Procedural Terminology code 95165, 95115, and 95117.” It is an open-access document that clearly outlines to payers which documentation is reasonable to request, and which is unreasonable. We sent this guidance directly to the medical leadership of the top health insurance companies across the country, emphasizing the importance of fairly paying these claims. This document supersedes any document or manual published previously by the above organizations.
- Seven Medicare Administrative Contractors (MACs) have agreed to pay allergists for build-up as well as maintenance doses of allergenic extracts. Their Sept. 18, 2025, Local Coverage articles state: “There is no differentiation between initiation therapy and maintenance therapy. However, claims for maintenance allergen immunotherapy require the EJ modifier.Diluted doses for the purpose of “build-up” and maintenance dosing are the same, as long as reasonable and necessary and within CMS National Correct Coding Initiative (NCCI) Medically Unlikely Edits (MUEs).”Because of the above ruling, it’s important to know the difference between “build-up” and “dilution” and to use the terms correctly when describing allergy extracts. CMS has stated that dilutions outside the initial build-up phase are not covered or separately paid for by Medicare. Therefore, these services should not be billed to Medicare to avoid claim denials or compliance issues.
In addition to these national issues, we know it is imperative that we keep our fingers on the pulse of allergy practices and allergists’ interests.
- During the College’s Annual Meeting each year, the Advocacy Council develops a letter on a specific issue and gives all members the opportunity to support the effort. In 2025, our letter to congressional representatives supported a permanent fix to Medicare’s Physician Payments.
- We sent a letter to Senators Mike Crapo (R-ID) and Ron Wyden (D-OR) expressing support for the PBM Price Transparency and Accountability Act.
- We endorsed Sen. Richard Durbin’s (D-IL) and Sen. Deb Fischer’s (R-NE) Protecting Children with Food Allergies Act, which funds food allergy training for school food service staff. This bill was signed into law by President Trump in January.
- The College’s Advocacy Council signed on to:
- The CHIME letter to HHS requesting rescission of the proposed HIPAA Security Rule
- AMA’s Federation letter in support of the Improving Seniors’ Timely Access to Care Act of 2025
- AAFA’s joint letters to 11 state Pharmacy and Therapeutics Committees regarding needle-free access to epinephrine for Medicaid patients
- We submitted comments to the American College of Physicians Policy Brief on its draft paper, “Reforming 340B to Promote Program Integrity and Better Serve Vulnerable Populations.” Our comments support reforms to the 340B Drug Pricing Program, including increased transparency, stronger program oversight, and ensuring drug discounts are used effectively to support the program’s mission.
- The College’s Advocacy Council submitted comments on the Democratic and Republican Doc Caucus’s MACRA Modernization RFI. The College’s Advocacy Council respectfully urged Congress to:
- Stabilize Medicare physician payments by developing and advancing long-term, sustainable solutions to the annual physician payment issue.
- Address statutory and regulatory flaws in MIPS through reform or replacement so that Medicare may move toward greater value-based care while reducing administrative burden on physicians.
- Funding for Graduate Medical Education (GME) has been a long-time top advocacy effort of ours. CMS recently announced the distribution of 400 new federally funded GME residency positions to hospitals across the country. This move, which primarily supports training in primary care fields like internal medicine, builds on congressional efforts to expand the physician workforce after decades of funding limitations.ACAAI’s Immediate Past President James Tracy, DO, initiated Pathways to Practice (P2P): Advancing Excellence One Fellow at a Time, which directly supports the training of 16 new allergy/immunology fellows through four competitive $250,000 (two-year) grants awarded each year, with fellowship positions beginning in 2026.The College’s Advocacy Council will continue to monitor and push for further GME expansions to ensure the allergy and immunology workforce can meet future demands.
Throughout the year, we help allergists, practices and state societies address countless payment issues. Our House of Delegates (HOD) has state delegates in almost every state to help raise your issues and have them addressed appropriately. Be sure you know your College State Delegate.
The Advocacy Council – ADVOCATING FOR ALLERGISTS AND THEIR PATIENTS.
