ASNC Readies for Rulemaking on AUC Program

Any day now, the Centers for Medicare and Medicaid Services (CMS) will release the 2016 Medicare Physician Fee Schedule (MPFS) proposed rule. In this rule, it is expected the Agency will take the first steps toward implementation of the congressionally mandated appropriate use criteria (AUC) program which takes effect Jan. 1, 2017.

CMS faces its first deadline on Nov. 15, 2015 when it must specify one or more AUCs that physicians can use to comply with AUC consultation requirements for advanced diagnostic imaging as set forth in the Protecting Access to Medicare Act of 2014. ASNC anticipates the upcoming rule will propose a process for specifying AUC, as well as for selecting qualified clinical decision support (CDS) mechanisms, which CMS must complete April 1, 2016, for ordering professionals to use when consulting AUC.

It is possible CMS will also begin to seek comment on other implementation aspects of the program, including the transmittal of information between professionals who order and furnish imaging tests, the establishment of hardship exceptions, and the process for identifying outlier ordering professionals.

Since enactment of the law, ASNC has prioritized its advocacy efforts aimed at the goal of ensuring that the Medicare AUC program fulfills a core tenet of AUC – making sure that patients get the right test first when a diagnostic test is indicated.

ASNC's advocacy efforts on your behalf have included meetings with CMS officials, congressional offices, and organizations representing ordering professionals. Let me be clear, success of the program is in our collective best interest. ASNC has been a leader in the development and promotion of AUC. But, let's also be honest. The law is complex and places new expectations on already overburdened primary care providers.

Success or failure of the AUC program ultimately hinges on how it is implemented and is why ASNC has called for a phased approach to the program that excludes nuclear cardiology from first-year implementation., ASNC designed AUC have already led to a significant reduction in inappropriate nuclear cardiology testing. Additionally, there is a need for more primary care provider education on use of AUC for complex cardiac conditions, and a need to address the significant propensity for test substitution by payer representatives. These all anchor ASNC's position of a phased approach. Ultimately, ASNC believes the broader imaging community is well-served by our position. Failure of the program to achieve reductions in imaging volume and cost puts us all at risk for more draconian policy changes including elimination of the in-office ancillary services exception (IOASE). We must appeal to CMS to implement the program in a way that encourages ordering professionals to use AUC and targets high volume imaging services for which adherence to AUC is not well-established and for which real volume reductions can be immediately achieved.

Once the MPFS proposed rule is released, ASNC will get to work on its analysis and formulating its comments, as well as providing information to help you and your practice prepare for Medicare 2016 and beyond. Thank you for your ongoing commitment to ASNC advocacy.