Mission Focused: CSRO Advocating for You

Rheumatologists Laud CMS’ Utilization Management, Marketing Reforms in Medicare Advantage

CSRO urged the Centers for Medicare and Medicaid Services (CMS) to finalize proposed policies that would meaningfully address longstanding challenges with utilization management (UM) and plan marketing in Medicare Advantage (MA).

In correspondence sent this week, CSRO highlighted the importance of the UM reforms for enrollees with rheumatic diseases, who often face delays in care as a result of these policies, calling on CMS to also expand its proposed policies to Part D. In addition, CSRO asked CMS to rescind its 2018 step therapy policies, or at a minimum, ensure they are aligned with the continuity of care proposals in the rule. Finally, CSRO urged CMS to finalize policies that would reform plan marketing, which would ensure potential enrollees are informed about the details surrounding the plan they are enrolling in. For MA plans that fail to comply with the policies, CSRO urged CMS to impose penalties, including civil monetary penalties, suspensions, and permanent bans from the program.


CSRO also joined the Alliance of Specialty Medicine (ASM) in sharing additional feedback on other important proposals that would impact specialty physicians and patients in MA plans, as well as targeted comments on utilization management by the Step Therapy Coalition.

Review CSRO's Comments

CSRO Urges CMS to Delay Rheumatoid Arthritis Cost Measure

Given feedback from rheumatologists and their practice administrators, CSRO sent a letter to CMS’ contractor, Acumen LLC, urging a delay in the use of the rheumatoid arthritis (RA) episode-based cost measure as part of the Quality Payment Program (QPP).

CSRO heard from practicing rheumatologists that the RA measure under development provides little information that would change their plan of care for RA patients and may cause more harm than good by focusing on cost factors that are outside their control. If CMS decides to use the measure, practice administrators asked the agency to provide bi-annual snapshots during the performance year so practices have a reasonable opportunity to make adjustments where appropriate.

Read the Letter

Amicus Briefs Filed in Suit to End Policy Prohibiting Copay Assistance From Counting Toward Patients’ Out-of-Pocket Spending

On February 9, CSRO joined over thirty provider and patient groups on an amicus brief in HIV and Hepatitis Policy Institute v. United States Department of Health and Human Services. This litigation was brought by the HIV and Hepatitis Policy Institute after the Administration announced in its 2021 Notice of Benefit and Payment Parameters that it would permit the use of copay accumulators in the Affordable Care Act exchanges.

Copay accumulators prohibit patients from counting the value of manufacturer copay assistance towards their deductibles, annual limits, and other cost-sharing. The amicus brief argued that the use of accumulators and similar tools by insurers negatively impacts patients living with chronic, serious conditions. Due to their high, ongoing medication needs, rheumatology patients are often confronted with accumulators and similar insurer cost-shifting tools, which is why CSRO has aggressively engaged in advocacy to limit or prohibit their use.

We hope that the large number of patient and provider groups on the brief will provide the court with a compelling real-world perspective from patients and their treating physicians with regard to copay accumulators.

Advocacy Insider: The Why and How of Advocacy

Earlier this month, CSRO hosted the second installment of our Advocacy Insider series, which highlights what advocacy really is and the simple things you can do to make a positive impact

The webinar focused on the "why" and "how "of advocacy; why you should advocate and how to best advocate, both explained by a former Congressional health policy staffer with insider knowledge on the information that is important to share with your elected officials.

Attendees also heard from CSRO Board Member Dr. Michael Brooks, along with President Dr. Gary Feldman, about their personal advocacy journies, before an overview of important issues on the horizon for CSRO in 2023. The webinar recording is now available in CSRO's Education Library check it out today.

View Recording

In the News: CSRO Winter Policy Update

The Winter edition of CSRO's bi-annual Policy Update is here!

The newsletter is available on our website and features exclusive updates on CSRO's state and federal advocacy activity.


If you're interested in a more in-depth discussion of the content shared in this edition, we encourage you to save the date to join us this August 25-27 in Austin, Texas at our annual Advocacy Conference.

View Policy Update

Our Issues: Priorities for the Year Ahead

CSRO is at the forefront of state, federal, and payer policies working to grant access, affordability, and relief for the rheumatology community.

Our advocacy work is constantly evolving and expanding to achieve the mission of CSRO: ensuring access to the highest quality care for the management of rheumatologic and musculoskeletal disease. View a full listing of CSRO's priority issues on our website, and click through to learn about what they are, how they impact you, and what CSRO is doing about them.

View Priority Issues

Legislation Around the Country

ICYMI: Opportunity For Action in Your State

The following states have active legislation that needs your support – make your voice heard today:

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.

Be sure to check out our interactive legislative map tool for additional details.

View Status Report



  • AB 874: Introduced. Hearing tentatively scheduled for 3/17/23

Biomarker Testing

  • SB 496: Introduced. Hearing tentatively scheduled for 3/17/23

Gold Card

  • SB 598: Introduced and referred to Rules committee


Step Therapy

  • HB 1183: Introduced and referred to Health and Insurance committee


Biomarker Testing Coverage

  • SB 976: Public hearing held 2/14/23
  • HB 6628: Public hearing held 2/14/23

Step Therapy

  • HB 5452: Referred to Joint Committee on Real Estate and Insurance


Biomarker Testing

  • HB 85: Approved by House

Rebate Pass Through

  • HB 343: Introduced


Non-medical Switching

  • SB 746: Filed

Biomarker Testing

  • HB 805: Filed

White Bagging

  • HB 203: Referred to Healthcare Regulation subcommittee


White Bagging

  • SB 1255: Introduced and assigned to Insurance committee


Rebate Pass Through

  • SB 8: Public hearing held


Gold Card

  • SSB 1100: Subcommittee recommends amendment and passage

Non-medical Switching

  • SF 86: Subcommittee recommends amendment and passage
  • HF 96: Subcommittee recommends passage


White Bagging

  • SB 149: Introduced and referred to Committee on Committees 


Biomarker Testing

  • SB 805: Hearing scheduled for 3/15/23
  • HB 1217: Hearing scheduled for 3/9/23

Step Therapy

  • SB 515: Hearing scheduled for 2/22/23
  • HB 785: Hearing scheduled for 3/2/23


Rebate Pass Through

  • HF 1711: Introduced and referred to Health Policy and Finance committee
  • SF 1319: Introduced and referred to Health and human Services committee


Rebate Pass Through

  • SB 2484: Died


Step Therapy

  • SB 268: Referred to Insurance and Banking Committee


White Bagging

  • SB 223: Tabled in committee


Biomarker Testing

  • AB 155: Introduced and assigned to Health and Human Services Committee


White Bagging

  • LB 448: Referred to Banking, Commerce, and Insurance committee, notice of hearing for 3/23/23


White Bagging

  • HB 513: Public hearing held 2/15/23



  • HB 1413: Approved by House, Transmitted to Senate

White Bagging

  • SB 2378: Public hearing held


Rebate Pass Through

  • HB 2853: Referred to Insurance committee
  • SB 879: Reported do pass as amended by committee

White Bagging

  • SB 13: Reported do pass by committee and referred to Retirement and Insurance committee


Rebate Pass Through

  • S106: Introduced and referred to Health and Human Services committee


Rebate Pass Through

  • HB 2180: Filed



  • SB 184: Approved by the Senate, transmitted to the House


Rebate Pass Through

  • H233: Introduced and referred to Health Care committee


Biomarker Testing

  • SB5074: Scheduled for public hearing on 1/20/23
  • HB 1450: Amended to limit to oncology, referred to Appropriations committee

White Bagging

  • HB 1253: Referred to Health and Wellness committee
  • SB 5213: Scheduled for executive session in Health and Long Term Care committee on 2/17/23

What's Happening in the Capitol

The 118th Congress started early with its focus on pharmacy benefit managers (PBMs): for example, Senators Cantwell and Grassley re-introduced the PBM Transparency Act from the previous Congress, and the Senate Commerce Committee held a hearing on the topic on February 16.

At the hearing, there was widespread bipartisan agreement that PBM business practices are causing serious harm to patients and driving independent pharmacies out of business, and that the industry is in need of meaningful oversight and transparency. The PBM Transparency Act does not go as far as the patient and provider community would like, in that the pass-through in the bill would accrue to the payer (not the patient), but it does include other positive and important pharmacy- and transparency-related provisions. Meanwhile, the House Energy & Commerce Committee listed PBM oversight on its agenda as one of its areas of focus this Congress.

Overall, this early and intense attention to the PBM industry provides a hopeful sign that Congress is serious about reform. CSRO will continue to monitor and provide updates as appropriate.

Mark Your Calendar: CSRO's 2023 Events

CSRO's Fellows Conference: March 10-11, 2023

An annual event curated by rheumatologists specifically for rheumatology fellows.

Regional Town Halls: Mondays in April & May

Hear advocacy updates specific to your area and network with your community members.

CSRO's Advocacy Conference: August 25-27, 2023

Join us in Austin for our Advocacy Conference and celebration of our 20th Anniversary! 

CSRO Resources for You

  • Payer Issues Reporting Form
  • Request assistance with any payer relation issues that may be impacting your patients or office.
  • 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.
  • Action Center
  • Use CSRO's Voter-Voice engagement platform to easily communicate and engage directly with your elected officials.
  • Policy Correspondence Archive
  • Easily access all of CSRO’s policy letters submitted to payers, state, and federal governments as an informational resource.
  • Career Center
  • Locate the perfect fit whether you're looking for new career opportunities or trying to find the right candidate.

Please visit the CSRO website for other news and updates, and do not hesitate to contact us with any questions at [email protected].
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