Dear Secretary Burwell and Acting Administrator Slavitt:
The undersigned national medical organizations are writing to express concerns regarding the
Centers for Medicare and Medicaid Services (CMS) implementation of Section 218 (b) of Public
Law 113-93, entitled the Protecting Access to Medicare Act (PAMA). Specifically, our concerns
are related to the possible consideration of Radiology Benefit Management (RBM) companies as
potential sources for the establishment of applicable appropriate use criteria, as well as any use
of RBMs for the enforcement of the prior authorization section for ordering professionals who
are outliers. We would also caution against CMS using this part of the statute as a gateway to
expand the use of prior authorization into other areas of physician payment policy.
Selection of Criteria Developers
As it pertains to Section 218 (b) (q) (2) (A), entitled Establishment of Applicable Appropriate
Use Criteria, our organizations strongly oppose the inclusion of Radiology Benefit Management
(RBM) companies as suitable criteria developers because we believe they do not qualify as a
“provider-led entity.” In our view, qualifying provider-led entities must be actively engaged in
the delivery of health care services, as well as unaffiliated with any insurance company. We also
believe it is important that the criteria used by CMS only be developed by national physician
organizations and we do not support the creation of any new federal bureaucracy to develop
appropriate use criteria.
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