Advocacy Update Apr. 29, 2025
IN THIS ISSUE / Apr. 29, 2025
AADA urges CMS to address No Surprises Act burden requirements for good faith estimates
Colorado allows dental hygienists to administer fillers, Botox despite dermatologist opposition
AADA and DermCAC highlight dermatologists’ qualifications for superficial radiation therapy
Regulatory Affairs
AADA urges CMS to address No Surprises Act burden requirements for good faith estimates
On April 23, the AADA offered recommendations to CMS (PDF) on the implementation of the No Surprises Act (NSA) requirements for good faith estimate (GFE) provisions for insured patients.
The regulation would require physicians to generate and electronically transmit GFEs for insured patients to their health plans within short timelines, but the technology and workflows are not yet finalized. Additionally, physicians may be required to coordinate with other clinicians involved in a service, increasing administrative complexity. Also, generating GFEs could cost about as much as generating claims, adding a significant burden for practices.
The AADA’s recommendations addressed the significant administrative and cost burdens that GFE requirements for insured patients could impose on practices, including short timelines, unclear clinician responsibilities, and the need to adopt new, unspecified technologies.
Our recommendations included:
Limiting GFE requirements to services furnished by the billing clinician
Exempting in-network clinicians from reporting billed charges or contracted rates
Fully testing electronic data standards across clinician types and practice sizes
Providing a multi-year transition period for implementation
These recommendations are consistent with the administration’s emphasis on deregulation and burden reduction.
State Advocacy
Colorado allows dental hygienists to administer fillers, Botox despite dermatologist opposition
On April 25, the Colorado state legislature unfortunately passed a bill allowing dental hygienists to administer Botox and fillers with supervision.
Recently, the AADA opposed state legislation (PDF) in Colorado that would authorize dental hygienists to administer fillers and neuromodulators for therapeutic indications and cosmetic applications. This authority would be added to what constitutes dental hygiene. While dental hygienists would be required to have direct supervision by a dentist, “direct” is undefined in the bill.
In 2024, the AMA adopted a policy on Dentist Scope of Practice Expansion, recognizing “the threat posed to patient safety when dentists and dental hygienists are authorized to practice medicine and administer procedures outside their level of education and training.”
Regulatory Affairs
AADA and DermCAC highlight dermatologists’ qualifications for superficial radiation therapy
The AADA and Dermatologic Medicare Contractor Advisory Committee (DermCAC) recently reinforced dermatologists’ qualifications to the Medicare Administrative Contractors (MACs) to provide superficial radiation therapies (SRT) as part of comprehensive skin cancer management, when appropriate, and addressed concerns about limiting the procedure to radiation oncologists.
The AADA expressed these concerns in joint letters (PDF) to all Medicare Administrative Contractors (MACs) — CGS Administrators, National Government Services, Noridian, Palmetto GBA, and Wisconsin Physician Services — that participated in the October 2024 Multi-Jurisdictional Contractor Advisory Committee Meeting on the use of superficial radiation therapy for nonmelanoma skin cancer.
The letters also emphasized the importance of preserving patient access by ensuring dermatologists remain eligible to furnish SRT under any future coverage policies.
Regulatory Affairs
AADA members appointed to RUC workgroups and subcommittees
The AADA is heavily involved in the AMA/Specialty Society RVS Update Committee (RUC), which is a volunteer group of physicians representing different specialties who make influential recommendations on how to value a physician’s work when computing health care prices in the U.S. The AADA ensures dermatology’s voice is represented in discussions that inform how services are valued and reimbursed under Medicare.
Several members of the AADA RUC team will serve on RUC workgroups and subcommittees through 2027:
Alexandra Flamm, MD, FAAD, and Beth Ann Drolet, MD, FAAD, have been selected to serve on the Relativity Assessment Workgroup (RAW), which oversees the review of the Resource-Based Relative Value Scale (RBRVS) and identifies potentially misvalued services.
Dr. Flamm and Ryan Hick, MD, FAAD, will both serve on the Multi-Specialty Points of Comparison (MPC) Workgroup, which maintains and evaluates the list of comparison codes used in the valuation of physician services.
Mollie MacCormack, MD, FAAD, will continue her role on the Practice Expense (PE) Subcommittee, which reviews direct practice inputs and addresses broader methodology issues related to practice expense valuation.
Howard Rogers, MD, PhD, FAAD, AADA’s RUC advisor, has been appointed to the Research Subcommittee, which supports the development and refinement of RUC methodology.
These appointments reflect the expertise and leadership of the AADA RUC team and reinforce the Academy’s commitment to supporting the accurate valuation of dermatologic services.
AADA News
Support dermatology congressional champions through SkinPAC
As of April 24, SkinPAC has raised $601,961 from 597 individuals. Help us keep up the momentum as we advocate for Medicare physician payment reform. SkinPAC helps strengthen our relationships on Capitol Hill and reinforces our grassroots and lobbying efforts.
Contribute online at www.skinpac.org or by texting SkinPAC to 71777. Email skinpac@aad.org with any questions.
The political purpose of the American Academy of Dermatology Association Political Action Committee ("SkinPAC") is to solicit and receive contributions to be used to make political campaign expenditures to those candidates for elective office, and other federal political committees, who demonstrate understanding and interest in the view and goals of the American Academy of Dermatology Association.
Contributions to SkinPAC are not deductible for federal income tax purposes. Contributions to SkinPAC must be made from your funds and may not be reimbursed. SkinPAC cannot accept contributions from corporate accounts. Any recommended contribution amount is merely a suggestion. All AADA members have the right to contribute more or less or refuse to contribute without reprisal. Federal law prohibits us from accepting contributions from foreign nationals. Federal law requires us to use our best efforts to collect and report the name, physical address, occupation, and name of the employer whose contributions exceed $200 in a calendar year.
