A Critical Opportunity to Improve Medicare Coverage for Allergy Immunotherapy
The following is being sent on behalf of Dr. Wes Sublett, Advocacy Council Chair:
As a leader of ACAAI’s House of Delegates, I am asking for your help NOW!
For more than a decade, the College has worked with stakeholders to modernize Medicare’s outdated billing policies for allergy immunotherapy.
Together, we achieved an important victory: Medicare coverage for the buildup phase of allergy shots.
Now, we have our strongest opportunity yet to finish the job — but only if all allergists speak up.
In the proposed 2027 Medicare Physician Fee Schedule, CMS acknowledges many of the concerns ACAAI has raised, including the confusion created by Medicare’s outdated definition of a 1cc aliquot/dose. Even more concerning, this outdated Medicare policy has increasingly been adopted by commercial insurers and Medicaid plans, extending its impact far beyond Medicare.
CMS now recognizes that its current policy has created uncertainty and that the disconnect between Medicare billing rules and standard allergy practice is creating barriers to patient care. But recognition alone is not enough. CMS is asking for additional evidence, and they need to hear directly from you.
This is a pivotal moment. This is our opportunity to show CMS that this is not simply an ACAAI issue — it is a nationwide problem affecting allergists, allergy practices, and patients. Every allergist. Every practice. Every local, state, and regional allergy society has a stake in the outcome. Your voice can make the difference.
Submit your comments to CMS by September 14. And please don’t wait until the deadline — submit them today, or at least this week.
Use the sample comment letter as your starting point. It is lengthy because there are many important issues that need to be addressed. You can submit it largely as written by adding your personal information in the sections highlighted in red. A general or template-based comment is far better than no comment at all.
But, if you can, make it personal. Tell CMS what happens in your practice. Explain why immunotherapy matters to your patients. Share a real example of a patient whose life was improved by allergy shots — or a patient whose care was delayed, disrupted, or denied because of reimbursement or insurance policies.
Those real-world experiences are exactly the evidence CMS needs to hear.
And if writing is not your strength, don’t let that stop you. Use AI to help. Tools such as ChatGPT or Claude can quickly transform the sample letter into a personalized comment based on your own experiences. If you don’t use AI yourself, ask a staff member in your office who does.
Submitting a comment does not have to take hours. But every voice matters, and silence could mean missing this critical opportunity to change policy.
Comments may be submitted electronically or by regular mail: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1848-P, PO Box 8016, Baltimore, MD 21244-8016. The deadline is firm: September 14.
CMS has opened the door. Now we need allergists across the country to walk through it — and make sure CMS hears allergy’s voice loud and clear. Please submit your comment today.
Sincerely,
J. Wesley Sublett, MD, MPH, FACAAI
Chair, Advocacy Council