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News & Press: Government Affairs News

AAOE Meets with CMS on AUC Requirements

Thursday, June 6, 2019   (0 Comments)
Posted by: Bradley Coffey, MA, O-CHCP, AAOE Government Affair
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Washington, DC - The American Alliance of Orthopaedic Executives (AAOE) met with representatives of Medicare's Appropriate Use Criteria (AUC) Program, including Centers for Medicare and Medicaid Services (CMS) Chief Medical Officer Kate Goodrich, MD,  and members of the AUC Coalition to encourage the agency to delay upcoming requirements for clinicians ordering advanced imaging to consult clinical decision support mechanisms (CDSM) to justify the orders. The program starts testing on January 1, 2020 with denials of payment for missing CDSM modifiers starting January 1, 2021.

AAOE and the AUC Coalition are asking for CMS to delay the 2020 testing period while we work with Congress to better align the AUC program with the Merit-based Incentive Payment System (MIPS). CMS was supportive of the statutory changes being pursued by the coalition to make the program more flexible for ordering clinicians but was hesitant to agree to a further delay of the program citing the need to please authorizers (Congress) and administration officials who are concerned about the perceived level of unnecessary imaging being performed on Medicare beneficiaries.

The coalition also highlighted our concerns that the testing period begins in January 2020 but CMS has yet to begin education on the new program. Coalition representatives were adamant that education efforts must be increased and soon in order to ensure that clinicians and their staffs are aware of the requirements of the program. CMS indicated that this education would begin once instructions to Medicare billing contractors are released.

Beginning January 2020, absent an intervention from CMS in the form of a delay, clinicians will be required to use the QQ modifier on claims for advanced imaging to indicate that they consulted a CDSM prior to ordering the imaging. Many specialty physician societies operate a CDSM tool and this is one of the issues highlighted by the coalition, many of the CDSMs available for use do not use the same guidelines to determine the appropriateness of an imaging order and are thus locked into the guidelines that the practice and/or the hospital have purchased.

This week, coalition members including AAOE are on Capitol Hill pushing legislators to pass legislation changing the AUC program from a stand-alone program to one incorporated under the Improvement Activities category of MIPS. Because the AUC Program was enacted by the Protecting Access to Medicare Act (2014), changes such as this have to be passed through the legislative process.

AAOE will keep you updated on the AUC program and any changes that occur prior to and during the testing phase in 2020.

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