Just as you were done revising your practice systems and processes for Meaningful Use and MACRA/MIPS, a new Medicare mandate came along. One of the biggest challenges for radiology practices right now is to be able to comply with the requirement that ordering physicians use a Clinical Decision Support Mechanism (CDSM) to consult Appropriate Use Criteria (AUC) when ordering MR, CT, PET and other specified nuclear medicine exams. This rule has been on the books since 2014, but it will begin to be implemented in 2020 followed by the imposition of penalties in 2021. This is not a voluntary bonus like Meaningful Use, or the avoidance of a small fee reduction under MIPS, but rather it means there will be NO payment to the radiologist for procedures performed without using the appropriate process.
Medicare’s requirement that ordering physicians begin to use clinical decision support mechanisms (CDSM) when ordering certain advanced imaging examinations will take effect next year, and most radiology practices are gearing up to be ready. Any CDSM will require a set of rules, or Appropriate Use Criteria (AUC), that will guide the decision-making process.
We’ve been watching the development of the Appropriate Use Criteria/Clinical Decision Support (AUC/CDS) requirement since 2014 when it was first included in the Protecting Access to Medicare Act (PAMA 2014). The latest Medicare Physician Fee Schedule (MPFS) confirms that the requirement to use CDS will begin this coming year on January 1, 2020, but imposition of any penalties associated with the referring physician’s failure to do so will be delayed until 2021. We are currently in a voluntary reporting period that runs through the end of 2019, so it’s a good time for every radiology practice to review where it stands with regard to this important Medicare regulation.