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.  

None of this should come as news, especially to readers of our blog^[*].  Hopefully your practice has been working toward identifying and implementing the systems necessary for compliance in both the hospital and in the imaging center or private practice.  Educating the ordering physicians is a key component, as many of them will not be as aware of this rule as radiologists are.  There is no penalty to the ordering physician for failure to use the system!  Only the radiologist is denied payment, so it is the job of the radiology groups (often in concert with their hospital) to educate, train and assist ordering physicians in the use of the systems selected.  Radiology business managers report that their current focus is to get hospitals and their employed physicians (including Emergency Department physicians) familiar and comfortable with the use of the ordering systems. 

To help facilitate this process for radiology groups, the American College of Radiology (ACR) recently released the AUC Toolkit that can be used to explain the mandate to referring providers.  It contains links to some articles that explain the background and history of Appropriate Use Criteria, something the ACR has long been promoting, as well as a link to the Medicare Learning Network fact sheet and a customizable letter in Word format that can be used to send to referring providers.  In addition, the ACR’s Clinical Decision Support web page contains a nice compendium of information and ideas for practices to use as they begin to identify the systems and processes they will implement. 

While sending a letter and other information to your referring physician offices is a good idea, a personal visit to deliver information specific to your practice will go a long way toward acceptance of the system.  By making specific recommendations your practice will be more certain that the systems used by the ordering offices will comply and integrate with your own medical records or Radiology Information System (RIS) so that the appropriate data is captured for submission to Medicare.  This will assure that you continue to be reimbursed for these services.  Since Medicare has opened a voluntary reporting period through the end of this year, it would be a good idea to have ordering physicians begin to use the systems immediately as you roll out your educational program rather than waiting until 2020. 

We cannot over-emphasize the importance of working together with your hospital or health system to get the word out to the ordering physician community.  Our blog will be updated regularly with any news related to the AUC/CDS mandate, or any other regulatory changes that will affect your practice.  Subscribe today!

[*] Some of our previous articles on this topic can be found here:

April 2019: Appropriate Use Criteria Revisions by the American College of Radiology

January 2019: Medicare’s AUC/CDS Mandate Will Begin Next Year

January 2018: A Review of Medicare’s Appropriate Use Criteria and Clinical Decision Support Mandate for Radiology Practices

Sandy Coffta is the Vice President of Client Services at Healthcare Administrative Partners.

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