AUC Mandate Update: ACR Proposes to Shift AUC Reporting Burden on Ordering Docs

Nearly six years after enactment of Medicare's Appropriate Use Criteria (AUC) Program for advanced diagnostic imaging, the American College of Radiology (ACR) has finally acknowledged challenges with the law's implementation and is calling for changes. Repealing the program has been a regulatory relief priority for ASNC. This spring, ASNC led a letter to Congress signed by 18 organizations calling for program implementation to be suspended.

ACR's Proposed Changes 

In letter to the Centers for Medicare & Medicaid Services, ACR proposes to shift the entire program burden on ordering clinicians. Specifically, ACR proposes the program be modified as follows:  
  • In lieu of requiring providers to report AUC consultation information on each claim for advanced diagnostic imaging services, ordering providers would self-attest to the consultation
  • Qualified clinical decision support mechanisms (CDSMs) would collect the AUC consultation information. Information generated by the CDSM would then be provided to CMS for retrospective review and annual audit
  • Practices that qualify for an advanced alternative payment model and practices participating in clinical trials would be exempt.
  • The prior authorization requirement for outliers and those who do not consult AUC at all would still apply.

ASNC's Concerns 

Even with the ACR's proposed changes, a fundamental question remains: Is the program, which was enacted prior to creation of the Quality Payment Program, necessary? ASNC notes that questions and concerns persist: 
  • How to assuage the administrative and cost burdens on all providers who order advanced diagnostic imaging services,
  • How data would be reported to CMS since CDSMs do not need to be connected to registries, and
  • How CMS would connect each order with the corresponding service. 

ASNC is continuing to push for a legislative solution because the Protecting Access to Medicare Act of 2014 requires implementation of the program, which is currently in an 
“educational and operations” testing period