Recent Advocacy Actions

| July 8, 2024

Recent Advocacy Actions

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 Travis Miller, MD, FACAAI, works together tirelessly to advocate for our specialty on a variety of issues – some of which are noted below. Direct your questions/comments to


Alternative Payment Models

  • Recommended that CMS develop alternative payment models with realistic and attainable incentives.

Antimicrobial Stewardship

  • Joined other medical specialties in supporting the Pasteur Act – legislation to strengthen the antibiotic/antifungal pipeline and increase support for antimicrobial stewardship programs.
  • Supported increased funding for antimicrobial resistance research.
  • Advocated for antimicrobial resistance to be included in the Pandemic and All Hazards Preparedness Act reauthorization.
  • Supporting increased funding for antimicrobial resistance in FY 2024.


  • Supported the funding request for the CDC’s National Asthma Control Program.

Electronic Funds Transfer Fees

  • Supported legislation that protects physician payments from electronic funds transfer fees.
  • Supported legislation attempting to prohibit EFT fees.


  • Supported the review of Emergency Medical Kits in airplanes at least every three years with the intention to get epinephrine products specifically for anaphylaxis  placed in the kits.

Food Allergy

  • Submitted comments on the FDA notice regarding front-of-the-package labels, raising concerns about the use of “nondairy” and “dairy-free” labels that can be misleading for milk allergy patients.
  • Opposed the addition of sesame in previously sesame-free products to the American Baker’s Association.
  • Supported a request to Congress for increased food allergy research funding in fiscal year 2024.
  • Joined the Food Labeling Modernization Act stakeholders’ group.

Insurance Issues

  • Advocated for CIGNA Insurance to revise its policy on providing patient notes for each claim where modifier -25 is used.
  • Joined with the AAAAI and AAOA to write a consensus statement about what should and should not be required when documenting allergy extracts as part of insurance claims and audits.

MIPS Value Pathway

  • Recommended more allergy/immunology measures for the 2024 MIPS program to CMS, including the addition of pneumococcal vaccination under the Allergy/Immunology Measure Set.
  • Submitted comments to CMS on their proposed Pulmonary MIPS Value Pathway (MVP).
  • Submitted comments on the Allergy/Immunology Specialty Measures set and the MVP Pulmonary Measure.
  • Submitting comments to CMS on 2022 MIPS scores, associated 2024 payment adjustments, and value-based payment opportunities for allergists – including APMs.

Miscellaneous Issues

  • JAMA published an article criticizing AMA’s Specialty Society RVS Update Committee’s (RUC) process and accused its medical specialty society volunteers of unprofessional and unethical behavior. As part of the Coalition of Sub-specialty Societies, we developed a response in support of the RUC.
  • Supported S.470/H.R. 977 – Legislation that supports the repeal of a physician self-referral law banning physician ownership of hospitals.
  • Supported Smoke & Heat Ready Communities Act – Legislation regarding the impact of wildfires’ smoke and extreme heat on vulnerable communities.
  • Supported the proposed rule that would update and advance protections for people with disabilities under Section 504 of the Rehabilitation Act of 1973.

Pharmacy Benefit Managers

  • Endorsed the Senate Finance Committee’s proposed legislation on Pharmacy Benefit Managers, which would prevent PBM reimbursement from being linked to drug prices, improve audit and enforcement measures, offer support to community pharmacies, and prohibit PBMs from receiving payments for drugs covered by Medicare Part D.
  • Endorsed the Senate Finance Committee’s legislation – Modernizing and Ensuring PBM Accountability Act – that addresses critical issues related to Pharmacy Benefit Managers (PBMs) and has the potential to improve the accessibility, affordability, and quality of health care for patients, particularly those with allergies, asthma, and immunological conditions. 

Physician Fee Schedule – Payment Reform

  • Urged Congressional action for an annual inflation-based physician payment update based on the full Medicare Economic Index (MEI).
  • Supported the AMA’s Physician Practice Information Survey. The practice-cost data collected will be used to advocate for physicians to accurately represent their practice, patients, and profession.
  • Continued support of Medicare Payment Reform.
  • Supported Medicare Payment System Reform – The Advocacy Council supports physician payment reform at every opportunity.
  • Contacted 1,200 members of Congress encouraging them to sign on to Representatives Ami Bera (D-CA) and Larry Bucshon’s (R-IN) Medicare physician reimbursement reforms bill.
  • Supported H.R 6683, which would offset the 3. 37% reduction to the 2024 MPFS Conversion Factor.
  • Continued to support H.R. 2474: Strengthening Medicare for Patients and Providers Act.

Policy and Technical Changes

  • Commented on proposals concerning the utilization management techniques by Medicare Advantage plans, as well as proposed changes to provider networks in the 2024 Policy and Technical Changes to the Medicare Advantage Program.
  • Developed comments to support the Teaching Health Center Graduate Medical Education funding provision of the Lower Cost More Transparency Act.
  • Reviewed and advised members on information-blocking issues.

Prior Authorization

  • Supported a collaboration with the AMA and other specialties advocating for prior authorization (PA) reforms including delay in care, improper denial of PA requests, and overturning previous denials.

Step Therapy

  • Supported a step-therapy coalition opposing the reinstatement of Step Therapy in Medicare Advantage plans.


  • Responded to HHS’ request for information on the Healthcare Workforce.
  • Continued to support requests for pediatric subspecialty loan forgiveness for underserved areas.
  • Added “allergists” to the role of supervising physicians in Ohio H.B. 102 – Licensed Advanced Practice Respiratory Therapists.
  • Supported Advancing Rural Care.
  • Responded to the House Ways and Means Rural Health Committee’s RFI on improving access to health care in rural and underserved areas.
  • Submitted comments to the Senate HELP Committee on the Bipartisan Primary Care and Health Workforce Act which would mandate a specific amount of funding per resident to be consistent through FY2028.
  • Submitted comments to the Senate HELP Committee in support of the investments in health care workforce training initiatives included in the Bipartisan Primary Care and Health Workforce Act.