Alliance Supports Legislation to Modernize the Medicare Physician Fee Schedule
Withdrawal of FDA Indoor Tanning Rule Undermines Progress on Skin Cancer Prevention
Alliance Submits Comments on Medicare Advantage and Part D Proposed Rule
Coalition Advocacy to Preserve Community-Based Part B Treatment (Specialty Spotlight)
ALLIANCE SUPPORTS LEGISLATION TO MODERNIZE THE MEDICARE PHYSICIAN FEE SCHEDULE
The Alliance of Specialty Medicine wrote a letter in support of H.R. 8163, the bipartisan Provider Reimbursement Stability Act, which seeks to modernize the budget neutrality mechanism of the Medicare Physician Fee Schedule (MPFS) and improve stability for physician reimbursement and patient access.
Physician reimbursement has been subject to year-over-year payment reductions threatening the viability of physician practices. This is due to the MPFS updates’ failure to keep pace with inflation or reflect current practice expense data. Moreover, physicians are still experiencing the impact of significant redistribution resulting from the Centers for Medicare and Medicaid Services (CMS) implementation of increased relative values for certain evaluation and management (E/M) services which triggered a significant redistribution of payments and negatively impacted many medical specialties.
The continued instability of the MPFS has led physicians to limit the number of Medicare patients they see or to consolidate their practices with larger hospital or health care systems, thereby increasing costs to the Medicare program. Other physicians will simply retire early and permanently close their doors.
H.R. 8163, introduced by Reps. Greg Murphy (R-NC) and Tom Suozzi (D-NY) aims to reduce payment volatility, update practice cost evaluations, and prevent automatic cuts caused by an outdated $20 million budget-neutrality threshold by increasing it to $54 million and indexing it to the Medicare Economic Index (MEI).
WITHDRAWAL OF FDA INDOOR TANNING RULE UNDERMINES PROGRESS ON SKIN CANCER PREVENTION
The recent decision by the U.S. Food and Drug Administration (FDA) to withdraw its 2015 proposed rule restricting indoor tanning bed use by minors represents a 
missed opportunity to strengthen national skin cancer prevention efforts at a time when incidence rates of melanoma and other skin cancer diagnoses remain a serious public health concern.
Indoor tanning is a well-established and preventable risk factor for skin cancer, contributing to more than 400,000 cases annually in the United States. As dermatologic surgeons who diagnose and treat skin cancer every day, members of the American Society for Dermatologic Surgery Association (ASDSA) see firsthand the consequences of ultraviolet radiation exposure associated with tanning devices, particularly among patients who began using these devices at a young age.
The proposed rule would have prohibited individuals under age 18 from using indoor tanning devices and required adult users to acknowledge the associated risks prior to use. These standards reflected longstanding clinical evidence linking early ultraviolet radiation exposure to increased lifetime cancer risk and represented a practical step toward reducing preventable disease.
Melanoma, the deadliest form of skin cancer, is strongly associated with indoor tanning exposure. Individuals who use tanning beds 10 or more times increase their melanoma risk by 34% and use before age 35 is associated with an almost 60% increase in risk. Melanoma also remains among the more common cancers affecting adolescents and young adults, reinforcing the importance of early prevention and risk-reduction efforts.
Indoor tanning devices expose users to ultraviolet radiation levels up to five times stronger than natural sunlight. The World Health Organization classifies tanning beds as “carcinogenic to humans,” placing them in the same category as asbestos and cigarette smoke. Despite declining use, indoor tanning remains prevalent among youth, with high school-aged individuals continuing to report usage.
Currently, 22 states and the District of Columbia restrict the use of indoor tanning devices by minors. In the absence of a federal standard, protections and requirements continue to vary across jurisdictions, creating differences in how prevention policies are implemented nationwide.
Reducing exposure to avoidable ultraviolet radiation remains one of the most effective strategies available to lower long-term skin cancer incidence and associated health care costs, which exceed $8 billion annually in the United States. Policies that prioritize prevention continue to represent one of the strongest opportunities to improve patient outcomes while supporting a more sustainable health care system.
ASDSA encourages Congress, especially the Congressional Skin Cancer Caucus, to support continued federal leadership on skin cancer prevention and to urge the FDA to reinitiate rulemaking to restrict the use of indoor tanning devices by minors. Advancing evidence-based safeguards that reduce exposure to known carcinogens is an important step toward protecting patients and strengthening national prevention efforts.
ALLIANCE OF SPECIALTY MEDICINE SUBMITS COMMENTS ON MAPD ADVANCE NOTICE
The Alliance of Specialty Medicine submitted comments to CMS on the CY 2027 Medicare Advantage (MA) and Part D Advance Notice, complementing its recent comments on the CY 2027 MA and Part D proposed rule. In the letter, the Alliance supported excluding diagnoses from unlinked chart reviews from MA risk score calculations while urging continued oversight of plan medical record request practices. The Alliance also encouraged CMS to strengthen the Star Ratings program with measures that address network adequacy, utilization management, and administrative burden to improve the quality and fairness of Medicare Advantage programs.
Coalition Advocacy to Preserve Community-Based Part B Treatment
Recently, the Coalition of State Rheumatology Organizations (CSRO) held several meetings on Capitol Hill to advocate for the Protecting Patient Access to Cancer and Complex Therapies Act (H.R. 4299). This bipartisan legislation is critical to ensuring continued access to Part B medications selected under the Medicare Drug Price Negotiation Program (MDPNP). CSRO was joined by the Patient Access to Community Treatment (PACT) Coalition, of which it is a member.
The Protecting Patient Access to Cancer and Complex Therapies Act would address an unintended consequence of the MDPNP that, if left unaddressed, would have a harmful impact on community physician practices. Under the Medicare Price Negotiation Program (MDPNP), Medicare can set a Maximum Fair Price (MFP) for select Part B drugs, which are typically administered in physician offices or hospital settings. Currently, physicians are reimbursed at the Average Sales Price (ASP) +6%, but 
the new rule would change this to the Maximum Fair Price (MFP) +6, blending MFP into ASP calculations. According to a recent Avalere study, this change could reduce Part B add-on payments by 42-61% in Medicare and 12-18% in the commercial market, threatening the financial viability of private physician practices that rely on the “buy-and-bill” model. This could force providers such as rheumatologists to transfer patients to hospitals, thereby increasing costs and potentially limiting patients’ access to medications.
The Protecting Patient Access to Cancer and Complex Therapies Act would remove physician Part B drug reimbursement from MDPNP negotiations, maintain reimbursement at ASP + 6%, and require pharmaceutical manufacturers to pay rebates to CMS for the difference between ASP + 6% and MFP + 6%. This aims to protect access to Part B medications for 60 million Medicare beneficiaries while ensuring cost savings for the government and reducing out-of-pocket expenditures for patients.
ALLIANCE SUBMITS COMMENTS TO CMS
ON “CRUSH” REGULATION RFI
The Alliance of Specialty Medicine submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to the agency’s Request for Information (RFI) on Comprehensive Regulations to Uncover Suspicious Healthcare Activity (CRUSH). In the letter, the Alliance raised concerns about utilization management burdens, including prior authorization requirements under the Wasteful and Inappropriate Service Reduction (WISeR) Model, as well as potential changes to Medicare’s claims submission deadlines and Medicare Advantage enrollment requirements. The full letter can be accessed by clicking on the link below.
