On Capitol Hill

CSRO Urges CMS to Withdraw MFN Proposals within GLOBE and GUARD Models

On February 20, CSRO submitted comments to the Centers for Medicare & Medicaid Services (CMS) expressing concerns about its proposed rulemaking that would incorporate a Most Favored Nation (MFN) policy for prescription drugs within the Center for Medicare & Medicaid Innovation (CMMI)’s new Global Benchmark for Efficient Drug Pricing (GLOBE) and Guarding U.S. Medicare Against Rising Drug Costs (GUARD) Models.

One of CSRO’s primary concerns regarding the GLOBE Model is CMS's expectation of increased use of white bagging under the Part D benefit for specialty drugs administered in office or facility settings, such as rheumatology practices. CSRO informed CMS that implementing white bagging would not be in the best interests of patients, as it could lead to higher out-of-pocket costs, delays in care, and a greater risk of improper handling of specialty medications. The practice would benefit pharmacy benefit managers (PBMs) and vertically integrated pharmacies at the expense of patients. CSRO also highlighted that the proposals could raise patients' out-of-pocket costs and create barriers to utilization management, further delaying access to rheumatologic care for beneficiaries. Given these concerns, CSRO urged CMS to withdraw the proposals and take action to enhance oversight of drug access disruptions and utilization management practices. Furthermore, they called for a comprehensive evaluation of the cost exposure faced by beneficiaries.

Legislation Around the Country

TN: CSRO Backs Legislation to Ban AFPs and Maximizer Programs

Earlier this week, CSRO submitted comments in support of SB 420, which aims to ban the use of alternative funding programs (AFPs) and maximizer programs for prescription drugs. CSRO supported the reintroduction of this bill, which is designed to ensure that patients can access the full benefits of copay and patient assistance programs for medications. In 2021, Tennessee demonstrated strong support for patients by enacting a law banning copay accumulator programs. However, after this law was passed, health plans and pharmacy benefit managers (PBMs) increasingly turned to copay maximizer programs as another way to increase profits from drug manufacturers at the expense of patients. Furthermore, third-party vendors known as AFPs began collaborating with employer-sponsored plans to provide alternative coverage options for specialty drugs through charitable assistance programs, manufacturer patient assistance programs, or drug importation. SB 420 would address these unfair practices by AFPs, health plans, and PBMs that seek to boost their profits at the expense of patients. CSRO’s comments were submitted to the Senate Commerce and Labor Committee ahead of their rescheduled hearing on March 10.

OH: CSRO Joins Broad Alliance of Patient and Provider Groups Calling for Biomarker Testing Coverage

On March 4, CSRO joined over 80 patient and provider organizations in sending a letter of support for HB 8. This legislation aims to ensure that patients with state-regulated insurance plans, including Medicaid, receive coverage for medically appropriate biomarker testing. Access to biomarker testing is essential for rheumatology patients, as it enables them and their rheumatologists to identify the most effective treatment options based on the patients' unique biomarkers. CSRO, alongside a coalition of organizations led by the American Cancer Society Cancer Action Network (ACS CAN), has been advocating for the passage of this bill in Ohio for the past three legislative sessions. CSRO is also a cosignatory of ACS CAN's state policy principles that promote increased access to biomarker testing.

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 find a status report of all CSRO’s priority bills at the state level.

Interested in learning more about CSRO’s engagement in the states? Visit our State Legislation Correspondence page to review the letters submitted to state legislatures on CSRO’s priority issues.

Click above to access CSRO’s new State Legislative Tracker to find the status of CSRO’s priority legislation affecting the rheumatology community and its patients at the state level.

Advocacy Conference: October 2-3, 2026

Join us in Washington, D.C. for CSRO’s flagship Advocacy Conference to learn, network, and strategize around patient access to care. Sign up for the Registration Launch here!

Business of Rheumatology Webinar: April 15, 2026

Join us virtually to gain practical insights into today’s biosimilar market and learn how to navigate these changes with confidence. Participants will walk away with strategies to choose biosimilars intentionally, protect practice margins, and improve patient access—while adapting to the evolving reimbursement environment. Register here!

State Society Conferences:

CSRO's state rheumatology society members host their own annual meetings throughout the year. Find a listing of these state-specific conferences on our website.

Action Center

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

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 Medscape.

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.