Senate Bill Pushes to Restart AUC Program Requirements

Senators Marsha Blackburn (R-TN) and Catherine Cortez Masto (D-NV) have introduced the Radiology Outpatient Ordering Transmission (ROOT) Act (S.1692), which would revive the Medicare Appropriate Use Criteria (AUC) Program for advanced diagnostic imaging. The AUC Program was created by the Protecting Access to Medicare Act (PAMA) of 2014. PAMA was originally slated to take effect in 2017 but, following technical challenges to implementation, the Centers for Medicare & Medicaid Services (CMS) rescinded all program regulations in November 2023. For more than 10 years, ASNC was a leading voice calling for the program’s rescission.

PAMA required clinicians ordering advanced imaging services to consult AUC using a CMS-approved clinical decision support mechanism and prove they consulted AUC on a claim form in order to be paid for the service.

Based on ASNC’s preliminary analysis of the bill, the ROOT Act would remove the real-time claims reporting requirement and instead require the healthcare professional furnishing the imaging test to document on the claim for the service the national provider identifier of the ordering professional.

Ordering professionals would still need to consult AUC using a Qualified Clinical Decision Support Mechanism capable of transmitting certain information to CMS, including whether the service ordered would adhere to the applicable AUC. CMS would be required to identify “low-compliant” ordering professionals and recommend to Congress mechanisms for improving compliance.

The bill has been referred to the Committee on Finance. Stay tuned to ASNC for updates.

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