On January 1, 2022, radiology practices and hospitals that perform certain imaging services for Medicare patients will be denied payment for those services unless they submit documentation that the ordering physician has consulted a Clinical Decision Support (CDS) system. This regulation was included a few years ago in Medicare rulemaking, but its effective date has been delayed several times. As of now, there is no reason to believe it will be postponed further, so practices that have not yet taken steps to install and implement a system have a narrow window of opportunity to get ready.
It’s a cold January here in the northeastern US, so it’s a good time to heat up plans to comply with the Medicare AUC Mandate! We have entered the official Educational and Operations Testing Period of 2020, which means that Medicare is ready to accept the Appropriate Use Criteria (AUC) modifiers and G-codes on claims now being submitted. Let’s first review what this Medicare mandate means and then make plans to get it operational in your practice.
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.
Appropriate Use Criteria Revisions by the American College of Radiology on April 10, 2019
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.
Medicare’s AUC/CDS Mandate Will Begin Next Year on January 29, 2019
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.
Radiologists are understandably nervous about the Medicare rule requiring the use of Appropriate Use Criteria and Clinical Decision Support (AUC/CDS) systems.