This week, CMS dropped the final 2017 Medicare Physician Fee Schedule, and the authors dedicated more than 100 pages of rule-making to appropriate use criteria (AUC) for advanced diagnostic imaging. The focus is on functionality requirements of the clinical decision support mechanisms (CDSMs), but CMS also signaled that the start date will be January 1, 2018, as previously proposed.
In the interest of expedience, the agency did not prescribe any particular IT standards, but it may consider doing so in future rulemaking as interested agencies such as ONC and AHRQ come to consensus around optimal CDSM standards.
The rule did reference work that the Clinical Quality Framework (CQF) has done to harmonize standards for electronic clinical quality measurement with those that enable shareable clinical decision support artifacts (such as AUC) using Fast Healthcare Interoperability Resources, a relatively new standard for exchanging healthcare information that uses a web-based suite of API technologies (such as HTTP-based REST protocols) considered much less cumbersome than other HL7 standards.
The final rule specifies that:
- the ordering physician consults specified applicable AUC from a CMS qualified provider-led entity for all advanced imaging orders;
- CDSMs vendors must submit applications now through March 1, 2017 (and qualified CDSMs will be announced by June 30, 2017).
In response to comments, CMS tweaked its proposed set of eight priority clinical areas that will be used to determine outliers, removing chest pain and replacing it with coronary artery disease (suspected or diagnosed) and suspected pulmonary embolism. The other six categories are headache (traumatic and non-traumatic), hip pain, low back pain, shoulder pain (to include suspected rotator cuff injury), cancer of the lung (primary or metastatic, suspected or diagnosed), and cervical or neck pain.
Let’s hope the agency announces CDSMs approvals as they occur and does not wait until the June 30, 2017, deadline.
Needless to say, a lot of work has to happen to implement AUC, and the big question, of course, is whether radiologists will show up for the party. As in all IT system implementations, change management is involved, and physician behavior is not easy to change. If radiologists don’t jump onboard, they should be prepared to cede influence to someone who will.
This is a tailor-made gift from the government to radiologists who are committed to adding value to the health care system. Press the snooze button at your own risk.
The ACR’s early coverage of the final rule included the following updates:
- CMS decreased the multiple procedure payment reduction (MPPR) from 25% to 5%;
- in an effort to move providers of x-ray services from analog to digital x-ray technology, CMS will reduce reimbursement for analog x-rays by 20% in 2017 and every year thereafter;
- radiographs acquired on CR will be reduced by 7% in 2018 through 2022 and 10% in all years thereafter;
- though three new mammography codes had been proposed to bundle mammography with CAD, CMS discovered system processing issues and will stick with the existing G-codes (G0202, G0204, G0206) in 21017, transitioning to the new codes in 2018; and
- CMS accepted the RUC recommendations for work RVUs for the new codes, which results in increased values for both diagnostic codes and no change for the screening code.