Starting January 1, 2018, the Protecting Access to Medicare Act (PAMA) will require referring providers to consult appropriate use criteria (AUC) prior to ordering advanced diagnostic imaging services (CT, MR, nuclear medicine exams and PET) for Medicare patients.
Providers can access imaging AUC via stand-alone electronic clinical decision support (CDS) systems or CDS software embedded in a physician’s electronic health record (EHR). The ACR anticipates providers documenting that they consulted AUC by entering a provider identifier likely to be called a “decision support number (DSN)” in the exam order.
The ACR-developed CDS — ACR Select® (digital ACR Appropriateness Criteria®) — can be integrated into most common EHRs. ACR Select is expected to meet PAMA requirements. CMS will announce approved CDS systems by June 30.
No rendering provider — radiologist or otherwise — may receive Medicare payment for an advanced imaging exam if the referring provider does not verify that imaging AUC were consulted. Ordering physicians cannot shift the requirement to consult the guidelines to radiologists. Imaging providers cannot perform AUC administrative duties for referring providers.
Imaging providers may refuse Medicare referrals lacking the DSN and not be competitively disadvantaged.