Dear Administrator Verma:
The undersigned organizations constitute the overwhelming majority of health care professionals
who order or furnish advanced diagnostic imaging tests. While committed to consultation of
appropriate use criteria (AUC) for advanced diagnostic imaging tests, we 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. We
therefore urge the Centers for Medicare and Medicaid Services (CMS) to delay the AUC
Program educational and operations testing year.
CMS should continue voluntary participation in the AUC Program through at least 2020.
Voluntary participation should not require consultation of AUC using a CMS qualified Clinical
Decision Support Mechanism (CDSM) nor should Medicare reimbursement be contingent upon
documentation of consultation on the furnishing clinician’s claim. Physicians and other health
care providers are unprepared for another significant regulatory requirement. Our societies, while
committed to educating providers about Medicare policies and mandates, continue to prioritize
investment in education and training for successful participation in Medicare’s Merit-based
Incentive Payment System (MIPS) and alternative payment models (APMs). Preparing
physicians and other providers for a Medicare AUC Program education and operations year that
requires use of a qualified CDSM and claims documentation will divert important resources and
attention away from meaningful quality improvement
…
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