Question:

What is the status of the appropriate use criteria? Did the final rule provide any updates?

Answer:

In the Medicare Physician Fee Schedule (PFS), CMS finalized policies regarding the appropriate use criteria (AUC) and the Clinical Decision Support (CDS) for the purposes of advanced diagnostic imaging services. As some may remember, this program was required by the Patient Access to Medicare Act of 2014. The penalty phase will start on January 1, 2023, or the first year after the conclusion of the public health emergency (PHE). Radiology providers and the American College of Radiology (ACR) recognize that “when fully implemented, the AUC program will be a valuable tool to ensure that Medicare patients receive the right imaging at the right time.” CMS has provided an array of solutions to claims processing issues that plagued the system and resulted in a program implementation delay. As specified in the final rule, CMS intends to use the time between now and the start of the penalty phase of the AUC program to extend a provider education initiative. This education goal will help guarantee that all ordering professionals are informed of the consultation requirements and that this information is required for imaging providers who are furnishing diagnostic imaging orders.

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