This post was contributed by American College of Radiology Chief Executive Officer William T. Thorwarth Jr., MD, FACR.
Health care is changing. From MACRA to ICD-10, the American College of Radiology (ACR) is addressing challenges that these shifts present and helping radiology transition to the new landscape. However, some changes do not present the challenges some suspect. They may actually help us with recurring issues.
For instance, pending regulations to be issued by CMS later this year, effective Jan. 1, 2018, the Protecting Access to Medicare Act (PAMA) will require referring providers to consult appropriate use criteria (AUC) before ordering advanced diagnostic imaging services (ADIS) — CT, MR, Nuclear Medicine and PET — for Medicare patients.
Providers can access imaging AUC at the point of care via electronic clinical decision support (CDS) systems or CDS software embedded in a physician’s electronic health record (EHR). Barring any changes by CMS, we anticipate providers documenting that they consulted AUC by entering a physician identifier that may be termed a “decision support number” (DSN) in the exam order. ACR developed CDS — ACR Select® (digital ACR Appropriateness Criteria®) — that can be integrated into most common EHRs. ACR Select is expected to meet PAMA requirements. CMS will announce approved CDS systems by June 30.
Imaging providers will not be competitively disadvantaged by this federal requirement.
No rendering provider can receive Medicare payment for ADIS if the referring provider does not properly document that AUC were consulted. All imaging providers can refuse such undocumented Medicare referrals. Imaging providers cannot perform AUC administrative duties for referrers (as many have with prior authorization). In other words, ordering physicians cannot shift the requirement to consult the guidelines to radiologists.
There is no facility “exempt” from these requirements to which providers can shift this Medicare imaging.
Due to rapid imaging growth in the late 1990s/early 2000s, CMS and private payers will continue to monitor and manage imaging utilization. The ACR offered the CDS/AUC solution to ensure appropriate imaging in a way that does not delay necessary treatment, interfere in doctor-patient decisions or penalize radiologists via arbitrary cuts.
By promoting CDS/AUC, radiology can position itself as a resource to hospital and health system administrators. This is a vital opportunity as medicine transitions from volume- to value-based care.
Communicate with referring physicians to ensure that they are aware of the forthcoming mandate.
Given the immediacy of this PAMA requirement, please take part in (with your referring providers) the CMS-funded Radiology Support, Communication and Alignment Network (R-SCAN™) — administered by the ACR.
Use R-SCAN to get familiar with CDS/AUC and obtain continuing medical education (CME) Credit and American Board of Radiology (ABR) maintenance of certification Part 4 Credit.
Also, please read the new ACR Clinical Decision Support (CDS)/AUC Frequently Asked Questions document.
- How are you preparing for CDS/AUC?
- How have you communicated about the federal requirement with referring physicians?
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