Joined by over 40 provider and patient organizations, CSRO submitted testimony and a multi-stakeholder letter to the Senate Appropriations Subcommittee on Labor-HHS urging inclusion of critical report language in the FY 2026 appropriations bill. The proposed language directs CMS to assess the impact of below-cost reimbursement and restrictive Medicare Advantage step therapy policies on certain physician-administered biosimilars. The groups emphasized how rebate-driven ASP distortions and step therapy requirements are making many biosimilars financially unviable for physicians to administer, thereby threatening patient access to essential treatments. This Senate request mirrors testimony submitted to the House Appropriations Committee earlier this year. 

CSRO Submits Comments on Medicare Deregulation

In response to CMS’ Request for Information on Medicare regulatory relief, CSRO outlined specific policy changes to reduce administrative burden, improve access to care, and preserve the viability of independent rheumatology practices. Among its recommendations, CSRO urged CMS to work with Congress to revise the Average Sales Price (ASP) reimbursement methodology for biosimilars distorted by manufacturer rebates, and to address site-of-service payment disparities and 340B incentives that drive consolidation. CSRO also called on CMS to use its existing authority to rescind or revise the 2018 Medicare Advantage step therapy guidance for Part B drugs, overhaul the Self-Administered Drug (SAD) Exclusion List policy to ensure access for patients who cannot self-inject medications due to physical or cognitive limitations, update medically unlikely edits (MUEs), and reduce audit duplication across contractors – including placing limits on excessive Medicare Advantage chart review demands that serve as de facto “code-mining” exercises. Finally, CSRO recommended expanding MIPS exemptions for small practices and suspending use of rheumatology cost measures that fail to account for access barriers beyond physicians’ control and have been rejected by expert consensus panels.

CSRO also signed onto a broader response submitted by the Alliance of Specialty Medicine, which emphasized the need for a complete overhaul of the Merit-Based Incentive Payment System (MIPS), expansion of specialty-focused alternative payment models, and long-term reforms to the Medicare Physician Fee Schedule.

Rheum for Action: Medicare Advantage Plans: Where’s the Advantage?

CSRO's Vice President of Advocacy & Government Affairs, Dr. Madelaine Feldman, discusses the need for Medicare Advantage plans to have more oversight and accountability.

Read the latest edition of Rheum for Action, CSRO's advocacy column authored by Dr. Madelaine Feldman and produced in partnership with Medscape.

PDAB Webinars: What You Need to Know in Oregon, Washington & Colorado

OR & WA: The Impact of PDABs on Patients and Providers

Tuesday, June 17

 12:00pm - 1:00pm PST

What are Prescription Drug Affordability Boards (PDABs), and what do they mean for access to care in Oregon and Washington?

Join CSRO and Caring Ambassadors on June 17 from 12-1pm PST for a discussion with Amish Dave, MD, MPH, and Lorren Sandt on how PDABs affect patient-provider decision-making, medication access and affordability, and how you can get involved.

CO PDAB: How New Upper Payment Limits Impact Prescribers & Patients

Monday, June 23

 6:00pm - 7:00pm MST

The Colorado Prescription Drug Affordability Board will be the first state Board to consider upper payment limits on prescription medications, including Enbrel, Stelara and Cosentyx. 

Join CSRO, ACTnow, AiArthritis, and Colorado BioScience Association on June 23 for a discussion on the impact these changes may have on prescriber reimbursement and patient access!

Legislation Around the Country

CO: First Delinking Bill Signed into Law

Colorado Governor Jared Polis signed into law the first in the nation delinking legislation, which will prohibit pharmacy benefit managers (PBMs) from earning income linked to the list price of a drug, prohibit PBMs from unnecessarily favoring more expensive drugs on formularies, and increase drug cost transparency for health plan sponsors. CSRO has long been an advocate for delinking at the state and federal level and repeatedly submitted comments to the state legislature and Governor Polis endorsing this measure. 

This legislation will disincentivize PBMs from preferring higher-priced medications because they will no longer benefit from the size of the rebate or fee. Instead, PBMs will be reimbursed on a flat compensation fee – a model currently used by several more transparent PBMs. This approach will improve program stewardship and beneficiary access to affordable, clinically driven coverage.

CT & NE: Governors Sign Biomarker Mandates into Law

Governors in Connecticut, Nebraska, and Oklahoma have all signed into law legislation that mandates coverage of biomarker testing for select state regulated health plans. In Connecticut, the legislature previously passed legislation in 2024 that required coverage for Medicaid patients. However, this 2025 law builds upon that to ensure that all state regulated health plans cover biomarker testing when supported by scientific and medical evidence. In Nebraska, the new law mandates coverage of biomarker testing coverage for some conditions, including autoimmune conditions, but does not provide the comprehensive list of diseases that have been adopted in other states. CSRO looks forward to continuing efforts alongside our coalition partners in 2026 to ensure that all patients in Nebraska have access to this important diagnostic tool. 

Twenty-five states have now mandated coverage for biomarker testing. CSRO is a proud member of the biomarker testing mandate coalitions and was vocal in advocating for the passage of these bills in Connecticut and Nebraska. 

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 view a full status report of CSRO priority bills.

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.

AK

• Prior Authorization | Step Therapy (SB133): Sent to Governor

CA

• PBM Reform (SB41): Referred to Committees on Health and Judiciary
• Prior Authorization (AB512): In Senate. Read first time. To Committee on Rules for assignment.

CO

• 340B Drug Pricing Program (SB71): Signed by Governor (05/29/2025)
• Delinking | PBM Reform (HB1094): Signed by Governor (05/29/2025)

CT

• Biomarker Testing Coverage (HB6771): Signed by Governor (06/02/2025)

DE

• Prior Authorization (SB12): Reported Out of Committee (Economic Development/Banking/Insurance & Commerce) in House with 9 On Its Merits

HI

• 340B Drug Pricing Program (HB712): Signed by Governor (05/29/2025)

IA

• PBM Reform | Rebate Pass Through | Copay Accumulator Adjustment Program Ban (SF383): Sent to Governor

IL

• 340B Drug Pricing Program (SB2385): Adjourned Sine Die 06/01

LA

• Rebate Pass Through | PBM Reform (HB264): Scheduled for concurrence on 06/11/2025.

MA

• 340B Drug Pricing Program (HB1296): Hearing scheduled for 06/10/2025 from 10:30 AM-01:00 PM in A-2
• 340B Drug Pricing Program (HB1107): Hearing scheduled for 06/10/2025 from 10:30 AM-01:00 PM in A-2
• 340B Drug Pricing Program (HB785): Hearing scheduled for 06/10/2025 from 10:30 AM-01:00 PM in A-2
• 340B Drug Pricing Program (SB819): Hearing scheduled for 06/10/2025 from 10:30 AM-01:00 PM in A-2
• 340B Drug Pricing Program (SB779): Hearing scheduled for 06/10/2025 from 10:30 AM-01:00 PM in A-2
• Delinking | PBM Reform (HB1082): Hearing scheduled for 06/10/2025 from 10:30 AM-01:00 PM in A-2
• Rebate Pass Through | PBM Reform (SB724): Hearing scheduled for 06/10/2025 from 10:30 AM-01:00 PM in A-2
• Rebate Pass Through | PBM Reform (HB1364): Hearing scheduled for 06/10/2025 from 10:30 AM-01:00 PM in A-2
• Rebate Pass Through | PBM Reform | Maximizer Program Ban | Copay Accumulator Adjustment Program Ban | Alternative Funding Program Ban (HB1234): Hearing scheduled for 06/10/2025 from 10:30 AM-01:00 PM in A-2
• White Bagging (SB777): Hearing scheduled for 06/10/2025 from 10:30 AM-01:00 PM in A-2

MI

• Prescription Drug Affordability Board (HB4544): bill electronically reproduced 06/03/2025

NC

• Non-Medical Switching (H434): Ref To Com On Rules, Calendar, and Operations of the House
• Prior Authorization (S257): Conf Com Appointed

NE

• Prior Authorization | Biomarker Testing Coverage (LB77): Signed by Governor (06/05/2025)

NH

• Biosimilars (HB117): Ought to Pass with Amendment #2025-2325s, MA, VV; OT3rdg; 06/05/2025; SJ 15

NV

• Gold Card | Step Therapy (SB495): Adjourned Sine Die 06/02
• Maximum Fair Price limit (AB259): Enrolled and delivered to Governor.
• PBM Reform (SB389): Signed by Governor (06/05/2025)
• PBM Reform | Rebate Pass Through | Delinking | Copay Accumulator Adjustment Program Ban (SB316): Adjourned Sine Die 06/02
• Prior Authorization | Step Therapy (AB290): Adjourned Sine Die 06/02
• Step Therapy (SB354): Adjourned Sine Die 06/02
• Step Therapy (SB337): Adjourned Sine Die 06/02

NY

• Biosimilars (A3973): REPORTED REFERRED TO RULES
• Biosimilars (S3485): PRINT NUMBER 3485A

OK

• 340B Drug Pricing Program (HB2048): Legislative Veto Override (05/28/2025)
• Prior Authorization | Step Therapy (HB1808): Enacted w/o Governor Signature (05/29/2025)

OR

• 340B Drug Pricing Program (HB2385): President signed.
• Prescription Drug Affordability Board (SB289): Effective date, January 1, 2026.

VT

• 340B Drug Pricing Program (H266): Delivered to the Governor on June 5, 2025

WI

• 340B Drug Pricing Program | Copay Accumulator Adjustment Program Ban | PBM Reform | Step Therapy (AB173): Representative Udell added as a coauthor
• Copay Accumulator Adjustment Program Ban | Maximizer Program Ban | Non-Medical Switching (SB203): Fiscal estimate received

OR & WA PDAB Webinar June 17, 2025

Join CSRO and Caring Ambassadors for a webinar on understanding the impact of PDABs on patients and providers in Oregon and Washington.

CO PDAB Webinar June 23, 2025

Sign up for this webinar discussing the Colorado Prescription Drug Affordability Board and how new upper payment limits may impact prescribers and patients.

Business of Rheumatology: August 20, 2025

CSRO's virtual seminar series to help support rheumatology practices in building and strengthening their business.

Advocacy Conference: September 12-13, 2025

Register now to join us in Dallas, Texas, for CSRO's annual Advocacy Conference! 

Virtual Advocacy Day: October 8, 2025

Save the date to advocate alongside CSRO as we host live conversations with health care leaders. Be notified when registration launches by clicking here!

Fellows Conference: March 6-7, 2026

Calling all rheumatology fellows! Mark your calendars to join us in New Orleans, Louisiana, for CSRO's annual Fellows Conference.

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.

Advocacy Council

Amplify your voice by assembling with other like-minded individuals to enhance CSRO’s advocacy initiatives.

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.