September 09, 2016

ACR Stresses AUC Start Date in MPFS Rule Comments

Implementation of mandatory appropriate use criteria (AUC) for advanced imaging topped a list of concerns expressed by the American College of Radiology (ACR) in comments submitted Sept. 2, 2016, to the Centers for Medicare and Medicaid Services (CMS) on the Calendar Year 2017 Medicare Physician Fee Schedule (MPFS) Proposed Rule.

The ACR asked CMS to adhere to a Jan. 1, 2018 implementation date for AUC to guide orders for advanced diagnostic imaging services (ADIS) program as mandated by the Protecting Access to Medicare Act of 2014 (PAMA).

The ACR is prepared to execute its AUC program under that schedule and can assist CMS in achieving the implementation date. The ACR’s AUC and a delivery mechanism capable of housing multiple AUC have already been integrated into major electronic health record solutions and have been widely deployed in the health care marketplace.

Further, the ACRSelect® free web portal, which provides access to ACR Appropriateness Criteria® and other AUC, is active and operational. It provides ordering health care providers with access to the AUC and the ability to generate and share evidence of the AUC consultation for those providers without integrated access.

The ACR urged CMS to maintain transparency in the AUC program by requesting that the centers release the applications from the approved qualified provider led entities (PLEs) to detail how they meet requirements laid out in the 2016 MPFS final rule and the forthcoming applications for qualified decision support mechanisms (QDSMs). Additionally, the ACR commented on the proposed priority clinical areas for use in determining physician outliers, the qualifications and application process for QDSMs and claims processing for program implementation.

The ACR supported CMS’ proposal to accept the Relative Value Scale Update Committee (RUC) recommended work relative value units (RVUs) for the new family of mammography codes. We also agreed with maintaining the existing technical component (TC) payment codes and not subjecting them to the sharp reductions that would have resulted from the recent RUC direct input recommendations and the subsequent CMS practice expense (PE) methodology recalculation. The ACR will continue to work with CMS to ensure appropriate reimbursement for mammography.

In addition, the ACR commented on these issues raised by CMS:

  • Practice expense inputs for digital imaging services
  • Clinical labor tasks associated with digital imaging services
  • Proposed update to the methodology for calculating the Geographic Practice Cost Index in the U.S. Territories
  • A payment incentive for the transition from traditional X-ray imaging to digital radiography and other imaging services
  • Phase-in of significant RVU reductions,
  • Proposed valuation of new and revised Current Procedural Terminology (CPT) billing codes
  • Practice expense refinements
  • Physician self-referral
  • Multiple procedure payment reduction, and
  • Quality provisions of the proposed rule

For questions on the 2017 MPFS proposed rule or the ACR comments on the rule, please contact Katie Keysor at kkeysor@acr.org.