As Congress in 2014 worked on legislation to replace Medicare’s physician payment formula, lawmakers also inserted a mandate for radiologists to consult with clinical decision support software before ordering advanced diagnostic imaging examinations that include CT, MRI, PET and nuclear medicine.
To be reimbursed by Medicare, physicians have to confirm the appropriateness of an exam by first consulting with an evidence-based clinical decision support system (CDS) before an exam is ordered. The mandate was to be effective in January 2017 but the Centers for Medicare and Medicaid Services has pushed that date back to at least mid-2017 as it continues to confer with the industry to determine how the confirmation process will work.
Session RC254 on the morning of November 30 at the RSNA 2015 conference in Chicago, “The New Federal Requirement for Imaging Decision Support,” will walk through the nuances of the mandate and CMS’ approaches for implementing it.
Stephen Herman, M.D., a thoracic radiologist for 25 years and now CEO at MedCurrent, a vendor of radiology CDS software, say new standards must be developed to support communication between CDS and electronic health records systems, and making sure that data Medicare requires in claims are automatically generated and sent to the EHR.
Work to create rules to certify clinical decision support systems and prescribe how CDS will specify the appropriateness of procedures also must be developed, Herman says. It looks like various trade associations will write the rules governing the appropriate use criteria; the American College of Radiology, he notes, already has a set of criteria.
But hospitals and other organizations could write their own rules if they get approval from CMS, Herman says. That flexibility is important, he adds. “At my hospital, if a patient is in with a shoulder problem, our radiologists like to use MRI, but a neighboring hospital likes ultrasound. Both work and are appropriate.”
The clinical decision support mandate for radiology, when it comes, may not pertain just to radiology for long but spread to other disciplines, Herman believes. “This CDS for radiology is just the beginning. More is going to follow after radiology.”
Radiologists will have to be especially careful in selecting a specific clinical decision support system. Practices and hospitals will decide on their own what to buy, but whatever they select had better make all of their own and referring physicians happy, Herman explains. “You’ll want to keep customers happy so you need to know that CDS comes in different flavors, so pick a user-friendly one.” MedCurrent during RSNA will exhibit at booth 2972.
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