Starting Jan. 1, 2020, the Protecting Access to Medicare Act (PAMA) requires referring providers to consult appropriate use criteria (AUC) prior to ordering advanced medical imaging services (ADIS) — CT, MR, Nuclear Medicine and PET — for Medicare patients. This start date was reconfirmed by the recently released proposed rule for the Medicare Physician Fee Schedule (MPFS), calendar year 2019.
Due to the complex nature of the AUC program, the Centers for Medicare & Medicaid Services (CMS) is implementing a phased rollout of AUC:
- July 2018 – Dec. 2019: Voluntary reporting period for early AUC adopters
- Jan. 2020: AUC program begins with one-year Educational and Operations testing period (with no penalties on rendering physicians for incorrect reporting)
During the Educational and Operations testing, ordering professionals will consult AUC and furnishing providers will report AUC consultation information on the claim, but CMS will continue to pay claims whether or not the information is correctly included. The agency notes that this educational period will allow professionals to actively participate in the program while avoiding claim denials during the learning curve.
What You Need to Know
This AUC consult must be documented via a CMS-qualified clinical decision support mechanism (qCDSM). Without a documented consult, furnishing providers will not receive Medicare reimbursement for the procedure.
Clinicians eligible to participate in the Merit-based Incentive Payment System (MIPS) can receive Improvement Activity points by consulting AUC via qCDSMs. These same eligible clinicians can also receive MIPS Promoting Interoperability bonus credit (if not exempt or choosing to report that category) as long as Certified Electronic Health Record Technology (CEHRT) is used to access the AUC.
Practices must implement and attest to consulting a qCDSM during the 2018 reporting period for at least 90 days. Organizations interested in maximizing MIPS Positive Payment Adjustment should implement a qCDSM by Sept. 2018 to meet the 90-day Improvement Activity/Promoting Interoperability reporting requirement.
Early implementation will help ensure a positive financial impact through MIPS Performance Categories and set the stage for a compliant PAMA implementation.
ACR Resources Can Help
Access all ACR resources regarding AUC/CDS at acr.org/cds.
- Read the detailed summary of AUC provisions of the proposed rule prepared by ACR staff.
- Use CareSelect Imaging ― ACR Select®, a digital representation of the ACR Appropriateness Criteria® for diagnostic imaging, is a module contained within CareSelect Imaging. ACR Select may be integrated with all major computerized ordering/EHR systems and is freely available to all providers via the ACR Select web portal. See other qualified Decision Support Mechanisms approved by CMS.
- Take part in the CMS-funded Radiology Support, Communication and Alignment Network (R-SCAN™) — administered by the ACR — with your referring providers. Use R-SCAN to get familiar with CDS/AUC, obtain CME Credit and receive ABR Maintenance of Certification Part 4 Credit.
- Review Imaging 3.0 CDS case studies to gain insights from other practices and departments that have successfully implemented clinical decision support systems.
ACR staff and physician volunteers will continue to analyze the AUC provisions of the proposed rule and coordinate with CMS. For questions, please contact Katie Keysor at firstname.lastname@example.org.