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. 11 to the Centers for Medicare and Medicaid Services (CMS) for the Calendar Year 2018 Medicare Physician Fee Schedule (MPFS) Proposed Rule.
The ACR asked CMS to adhere to a Jan. 1, 2019, implementation date for AUC to guide orders for advanced diagnostic imaging services as mandated by the Protecting Access to Medicare Act of 2014 (PAMA). The ACR also supported a one-year “educational and operations testing period” to temporarily exempt furnishing physicians from penalties when consultations are incorrectly reported on their imaging claims.
The ACR is prepared to execute its AUC program according to this schedule and can assist CMS in achieving the implementation date. The ACR’s AUC and a delivery mechanism capable of housing multiple AUCs have already been integrated into major electronic health record solutions and have been widely deployed in the health care marketplace.
The ACRSelect® free web portal, which provides access to ACR Appropriateness Criteria® and other AUCs, 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 also provided specific recommendations to streamline claims processing for the AUC program. The College recommended requiring a unique consultation identifier on orders submitted to furnishing professionals so they may report it on their claims. The identifier would alleviate the need to develop a complex series of G-codes and modifiers.
In addition, the ACR commented on these issues raised by CMS:
- Payment incentive for the transition from traditional X-ray imaging to digital radiography and other imaging services
- Preservice clinical labor for 0-day and 10-day global services
- Updates to prices for existing direct practice expense (PE) inputs
- Practice expense refinements
- Proposed valuation of specific codes
- Determination of professional liability insurance relative value units (PLI RVUs)
- Medicare telehealth services
- Proposed payment rates under the MPFS for nonexcepted items and services furnished by nonexcepted off-campus provider-based departments of a hospital
For questions on the 2018 MPFS proposed rule or the ACR comments on the rule, please contact Katie Keysor at firstname.lastname@example.org.