Advocacy Update March 3, 2026
IN THIS ISSUE / March 3, 2026
Dermatology pursues immediate CMS action, LCD reconsideration on SRT training
Dermatologists urge support for Rhode Island step therapy reform
Regulatory Advocacy
Dermatology pursues immediate CMS action, LCD reconsideration on SRT training
Despite AADA’s opposition, five Medicare contractors (NGS, WPS, Palmetto, Noridian, CGS) have finalized Local Coverage Determinations (LCDs) related to superficial radiation therapy (SRT) for the treatment of nonmelanoma skin cancers.
Effective March 1, the policy will recognize dermatologists as qualified physicians to perform SRT but impose a restrictive requirement that training be obtained exclusively through accredited residency or fellowship programs. The AADA consistently expressed concern that this restrictive language does not reflect how dermatologists acquire competency in evolving technologies and would exclude appropriately trained physicians from delivering SRT.
The AADA has actively engaged CMS on this issue — particularly around training requirements for dermatologists performing SRT. The Academy requested an urgent meeting with CMS to seek immediate action, including delays of enforcement and safeguards to prevent interruption of care for patients with skin cancer. Additionally, the AADA and the Dermatologic Contractor Advisory Committee, which serves as a national coalition of dermatologist representatives selected by their respective state dermatology societies committed to monitoring local Medicare policy issues, have formally requested reconsideration of the LCDs from the Medicare Administrative Contractors and is seeking meetings with each MAC.
Until there is further clarification, physicians will need to make individual clinical and business decisions regarding whether to pause treatment, continue treatment without charge, or issue an advance beneficiary notice of non-coverage. Please use the Advance Beneficiary Notice of Noncoverage (ABN) form for your Medicare patients where Medicare payment is expected to be denied.
The Academy will continue pressing for a resolution.
State Advocacy
AADA, NY dermatologists oppose lab director requirements
The New York State Dermatology and Dermatological Surgery Society (NYSDDSS) and AADA urged the New York Department of Health to oppose excluding dermatologists and only allowing board-certified pathologists as lab directors.
In a joint letter (PDF), the AADA opposed proposed state regulations for lab directors where only physicians certified in anatomic or clinical pathology are qualified to serve as lab directors based solely on board certification. If implemented, this would remove a longstanding pathway that acknowledges board certification in dermatology as an indicator of training and expertise in laboratory oversight.
The proposed New York regulation is similar to the one that CMS suspended in response to AADA’s advocacy; that controversial CLIA policy also failed to recognize the lab qualifications of dermatologists.
Reimbursement Advocacy
Watch your inbox for an important AADA RUC survey
The Academy will launch two physician work surveys to collect data on revised current procedural terminology (CPT) codes as part of the AMA/Specialty Society RVS Update Committee (RUC) process. Members who are randomly selected are encouraged to review the survey carefully and complete it promptly if they are familiar with the work required to perform the service.
The data collected will be a critical factor for time and value recommendations to the CMS, with final values to be published in the Medicare Physician Fee Schedule.
RUC (PDF) is an expert panel of physicians, including dermatologists, who make recommendations to the federal government about the resources required to provide medical services. Although the RUC provides recommendations, CMS makes all final decisions about Medicare payments through rulemaking each calendar year. Learn more about the RBRVS RUC Update Process (PDF).
If you have questions, or for more information, contact Cameron Huff, Manager of Payment Policy or Jillian Dunn, Associate Director, Health Policy & Payment.
AADA News
AADA presents at FDA’s annual compounding listening session
State Advocacy
Dermatologists urge support for Rhode Island step therapy reform
The AADA and Rhode Island Dermatology Society urged Rhode Island legislators to support legislation that would require insurers to create an easily accessible and transparent process for physicians to seek a step therapy exemption if the physician determines the step therapy would be medically inappropriate.
The insurers would be required to expeditiously respond to such requests.
The bills are being considered in the House and Senate Committees on Health and Human Services. The AADA and other members of the State Access to Innovative Medicines Coalition met with the bill sponsor, Senator Linda Lee Ujufisa, on Feb. 27 to discuss.
AADA News
Contribute to the voice of dermatology
As of Feb. 26, SkinPAC has raised $198,416 from 167 individuals. Contribute online at www.skinpac.org or by texting SkinPAC to 71777.
SkinPAC helps strengthen our relationships on Capitol Hill and reinforces our grassroots and lobbying efforts. Your contribution today will help ensure we have the resources we need to ramp up our fight to reform Medicare physician payment in Congress. 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.
