Proposed Texas "Gold Card" Regulations: CSRO Comments
In 2021, Texas enacted first-of-its-kind legislation requiring certain state-regulated payers to exempt providers from prior authorization requirements for which they consistently receive approvals. These exemptions, also known as “gold cards,” are designed to reduce the burden of prior authorization requirements that do not serve a meaningful role in controlling unnecessary utilization.
CSRO is excited that states across the country are considering innovative solutions to the administrative burden issues created by prior authorization. New approaches are needed to tackle this problem. Requiring use of gold cards by health plans certainly qualifies as such, but as with any innovative policy it also raises numerous questions regarding how it will work in practice.
The Texas Department of Insurance (TDI) recently issued proposed rules designed to help clarify some of these operational questions in anticipation of the law going into effect. CSRO took the opportunity to comment on some of the questions TDI answered in their proposal, and to raise questions that the proposal did not address.
Some highlights include requesting TDI to:
  • finalize the clarification that prescription drugs are eligible for exemptions
  • clarify how a preauthorization exemption interacts with other utilization management restrictions
  • clarify how appeals and exception requests are counted when determining whether to issue an exemption
Once TDI finalizes its rules, CSRO will post content on its map tool to guide rheumatologists through the components of the new law.
Reminder: FTC Comments due May 25
The Federal Trade Commission (FTC) has requested input from the public about pharmacy benefit managers (PBMs) and their impact on drug pricing and access to medication.

Submit comments using CSRO's talking points by May 25 to ensure the physician perspective is represented.
Mark Your Calendars: State Society Advocacy Conference
Save the date to join CSRO this September 9-10 in Rosemont, Illinois for our 2022 State Society Advocacy Conference (SSAC).

Held annually, this conference brings together like-minded rheumatologists and advocates to network within our community, learn from nationally-recognized experts, and strategize about advocacy.

Don't miss it! Keep an eye out for the launch of registration and our keynote speaker announcement coming soon.

Advanced registration available: Member societies of CSRO receive a stipend to pay for transportation and lodging expenses for up to two representatives to attend the conference and annual business meeting. If you are interested in representing your state society at the SSAC, email us for advanced registration information.
Legislation Around the Country
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. For a full status report on all the bills CSRO tracks, click here.

Be sure to check out our interactive legislative map tool for additional information about current policy in your state. Plus, don't forget to add your state to your email profile here to receive state-specific updates and action alerts via email.
Non-medical Switching
  • HB 1370: Signed into law
Step Therapy
  • HB 1370: Signed into law
Prior Authorization “Gold Card”
  • SB 112: Pharmacy services amended out of legislation, passed Senate, approved by House committee, passed to third reading
Accumulator Programs
  • LD 1783: Enacted into law without signature
Rebate Pass Through
  • HB 1224: Reported favorably by Financial Services committee and referred to committee on Health Care Financing committee
Accumulator Programs
  • S5299: Amended on third reading
  • A1741: Passes the House and transmitted to the Senate
Step Therapy
  • SB 1310: Signed into law
Save the Date!

Find all of CSRO's event dates by visiting our Upcoming Events page, and check out past events and webinars in our Library.
Please visit the CSRO website for other news and updates, and do not hesitate to contact us with any questions at
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