Physician groups want relief from appropriate use criteria program

A wide range of healthcare organizations are asking Congress to relent on appropriate use criteria to order diagnostic imaging exams.

A total of 28 medical organizations sent a letter to lawmakers asking for a reduction in unnecessary reporting requirements related to the program, which will affect the way clinicians order certain types of outpatient diagnostic imaging exams prescribed for Medicare beneficiaries.

In the letter, physician organizations representing primary, specialty and surgical care ask lawmakers to modify the Protecting Access to Medicare Act of 2014, which established the Medicare Appropriate Use Criteria (AUC) Program, so that healthcare professionals who meet the requirements of the Medicare Quality Payment Program (QPP) will be deemed compliant with the AUC Program.

The Medicare Appropriate Use Criteria (AUC) Program for Advanced Diagnostic Imaging was originally scheduled to begin this past January, but organizations representing radiology professionals had been asking CMS to delay implementation, citing a lack of specifics for how the program would work and workflow challenges that healthcare organizations hadn’t ironed out.

Now, a broader range of medical groups are decrying the program, saying AUC consultation is inherent within the Merit-based Incentive Payment System (MIPS) and alternative payment models (APMs), both of which hold clinicians accountable for appropriate resource use.



While clinicians have embraced clinical decision support and evidence-based AUC, a stand-alone AUC reporting program duplicates the cost reduction and value-based activities of MIPS and APMs. Moreover, because there is a lack of appropriate measures, the AUC program will not aid in determining whether patients are better served by the program’s implementation, the groups contend.

The letter was sent to the leaders of the Senate Finance and House Ways and Means and Energy and Commerce committees.

“Nearly 60 percent of respondents to a study conducted by the Association for Medical Imaging Management estimate it will cost $75,000 or more for a practice to implement a CDSM,” the groups’ letter states. “Physician practices and hospitals will also incur additional costs to update their billing systems to transmit necessary AUC data to CMS. CMS estimates 579,687 ordering professionals will be subject to this program; yet, CMS admits that information on the benefits of physicians adopting qualified CDSMs or automating billing practices for specifically meeting the AUC requirements in this proposed rule does not yet exist, and information on benefits of the program overall is limited.”

The program also will affect the programming of electronic health records systems, the groups say.

“The CDSM tools are not all embedded in electronic health record (EHR) systems, thereby requiring ordering professionals to use an additional software program outside of their regular EHR,” the letter states. “Furthermore, free tools for physicians who cannot afford CDSM tools, especially those in small and rural practices, simply transfers the cost of CDSM acquisition to increased administrative burden.”

Groups signing the letter include the American Medical Association, American College of Physicians, American College of Osteopathic Surgeons, American Osteopathic Association and about two dozen other specialist organizations.