November 10, 2017

ACR Reassured About CDS Delay In MPFS Final Rule

After conducting a detailed review of the 2018 Medicare Physician Fee Schedule Final Rule, the American College of Radiology (ACR) remains supportive of the Centers for Medicare and Medicaid Services’ (CMS’s) decision to delay starting the Medicare’s Congressionally mandated clinical decision support (CDS) program until January 1, 2020.

In response to the ACR and other stakeholders, CMS abandoned its proposal to use a complex series of G-codes and modifiers to report consultation of appropriate use criteria (AUC) for advanced diagnostic imaging services. Instead, CMS will develop a system that uses the unique consultation identifier produced by qualified clinical decision support mechanisms. The ACR believes these changes will lead to a more streamlined and less burdensome claims processing system.

In addition, CMS will continue to explore opportunities for stakeholder education and to address other suggestions and concerns raised during the proposed rule comment period. These include clarification on what will be expected during the one year “educational and operations testing period,” possible expansion of the significant hardship exceptions, clarification on who is authorized to perform the AUC consultation, and details about implementation of the statute’s physician outlier provision.

Though there is no formal comment period for this rule, the ACR will submit comments to CMS on implementing the AUC program and will continue to engage with the agency to ensure its smooth execution. A detailed summary of the AUC section of the 2018 Medicare Physician Fee Schedule final rule can be found on the ACR website. For questions, please contact Katie Keysor at