The swiftness of CMS' timeline for implementing appropriate use criteria changes for advanced diagnostic imaging services would undermine physicians' efforts to improve quality and limit administrative burden, the Academy recently told the agency.
In an April 29 letter(2 page PDF) to CMS Administrator Seema Verma, M.P.H., the AAFP and 21 other medical organizations said the AUC program's(www.cms.gov) educational and operations testing year should be delayed, with voluntary participation extended through at least 2020.
And such participation, the letter added, should not require consultation of AUC using a CMS-qualified clinical decision support mechanism or make Medicare reimbursement contingent on consultation documentation.
Readying physicians for an education and operations year that requires this new paperwork, the letter warned, "will divert important resources and attention away from meaningful quality improvement."
"Physicians and other health care providers are unprepared for another significant regulatory requirement," the letter added, pointing out that implementation in 2020 would run counter to CMS' Patients Over Paperwork initiative(www.cms.gov) and add fresh administrative burdens to physicians across specialties.
"By CMS' own admission, information on the benefits of physicians adopting qualified CDSMs or automating billing practices for specifically meeting the AUC requirements (does) not yet exist," the letter said.
Bolstering its case for a more deliberate transition, the letter pointed out that much has changed in the five years since the Protecting Access to Medicare Act established the AUC program. For one, physicians are now incentivized through Medicare's Merit-based Incentive Payment System "to improve health care quality and reduce resource use."
Meanwhile, the letter added, "Medicare is requiring alternative payment model participants to assume more downside risk, and imaging volume has dropped 0.2%, on average, over the last five years, with advanced imaging accounting for only 4.7%(www.medpac.gov) of total Medicare allowed charges in 2017.
"Given these developments, the AUC program amounts to another administrative layer with benefits not well-articulated."
The signing organizations noted that they represent "the overwhelming majority of health care professionals who order or furnish advanced diagnostic imaging tests" and that they "are unconvinced the Medicare AUC program, including the 2020 education and operations year, can be implemented without significant disruption to physicians, hospitals and other health care providers."
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