Comment on CMS-2026-2377-0002

Summary: Dr. Stephen Fritz, President of Portland Allergy and Asthma, supports the proposed rule's recognition of the need to update the definition of a "dose" for CPT code 95165. He urges CMS to adopt the CPT definition (a single injection from a multidose vial) and to eliminate or significantly increase the Medically Unlikely Edits (MUE) cap to ensure patients receive appropriate, individualized immunotherapy.