Regulatory Resources

AUC Update

Last summer, the Centers for Medicare and Medicaid Services (CMS) indefinitely delayed the payment penalty phase of the Appropriate Use Criteria (AUC) policy. This indefinite delay was announced via a “notice” posted on the official AUC webpage and there has been no other communication on AUC in the last 8 months.In that time, the AHRA Regulatory Affairs Committee has met twice with CMS staff to inquire as to what the next steps might be for the AUC policy. It is difficult to predict with certainty, but we believe that CMS will provide an update to the imaging industry in the 2024 Physician Fee Schedule rulemaking process. While this update may give us additional insight into CMS’s current thinking, at this time, it seems unlikely that CMS will propose a new start date for the payment penalty phase in their proposed rule this summer.We continue to emphasize to CMS staff that if they choose to reinvigorate the AUC policy by rescheduling the start of the payment penalty phase, adequate advanced notice of at least a year should be provided to the imaging community.While this issue has settled into a status-quo of indefinite uncertainty, you can rely on AHRA to closely monitor any policy updates. We will be sure to cover any meaningful news regarding AUC on AHRA.org.

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Clinical Decision Support Survey - June 2019
 While reporting under the Medicare Appropriate Use Criteria (AUC) program will be required starting on Jan. 1, 2020, this will be an educational year during which CMS will not deny claims through Dec. 31, 2020 that incorrectly report AUC information. However, radiology providers will begin to see claim denials starting on January 1, 2021, if the AUC consultation data (i.e. G-codes, modifiers and NPI) are not reported on the claim. It's important for administrators and providers to begin developing an implementation strategy this year to allow time to test systems, train providers and staff and introduce new processes. In June of 2019, AHRA surveyed members to assess readiness.
Click here to view results.

Radiology Assistant (RAA/RPA) Survey - June 2019
The Centers for Medicare & Medicaid Services (CMS) is revising its policy to specify that beginning with dates of services on or after January 1, 2019, diagnostic procedures that are furnished by a Radiologist Assistant, who CMS defines as either RRAs, who are certified by The American Registry of Radiologic Technologists, and RPAs, who are certified by the Certification Board for Radiology Practitioner Assistants, require only a direct level of physician supervision, when permitted by state law and state scope of practice regulations. CMS notes that for diagnostic imaging tests requiring a general level of physician supervision, this policy revision does not change the level of physician supervision to direct supervision.
Click here to view results.

Clinical Decision Support Survey - June 25, 2018
In the Protecting Access to Medicare Act (PAMA) of 2014, Congress included a mandate - also known as the CMS Appropriate Use Criteria program (AUC) - which requires ordering providers to consult AUC via an electronic Clinical Decision Support Mechanism (CDSM) when ordering outpatient advanced imaging exams for Medicare patients. Medicare has delayed the CDS provider deadline to January 1, 2020. AHRA’s Regulatory Affairs Committee, in an effort to understand how prepared members are and to understand the challenges they face, recently conducted a survey. The information from this survey will be used to help operationalize the process to flow from the order through to the billing forms, including hospital technical, global, and professional environments, without manual intervention by imaging and billing staff.
Click here to read a summary of this survey.
Click here to view the results.

CR/DR Survey - March 2, 2018
The AHRA conducted surveys to better understand how members are responding to a provision in the Consolidated Appropriations Act of 2016 that incentivizes imaging providers to adopt DR technology over CR and plain X-Ray.
Click here to read a summary of the recent surveys.
Click here to view the results.

Clinical Decision Support Survey - March 1, 2017
The Protecting Access to Medicare Act (PAMA) of 2014 established the Appropriate Use Criteria program with the goal of increasing the rate of appropriate advanced diagnostic imaging services provided to Medicare beneficiaries. Under this program, at the time a practitioner orders an advanced imaging service for a Medicare beneficiary, he/she will be required to consult a qualified Clinical Decision Support Mechanism (CDSM). Recently, the AHRA surveyed members to assess preparedness.
Click here to read a summary of this survey.
Click here to view the results.

Videos (Generously provided by ITNonline)
AHRA Regulatory Update Part 1: Clinical Decision Support AHRA Regulatory Update Part 3: Site-Neutral Payment

Infographics:
            

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