Update on Radiology Regulations

Extension Granted for Appropriate Use Criteria for Advanced Imaging

The Centers for Medicare & Medicaid Services (CMS) delayed the effective date for the Appropriate Use Criteria (AUC) consultation and reporting requirements to 
Jan. 1, 2020, and made several other changes to the policy. On and after Jan. 1, 2020, radiology professionals who order certain advanced imaging services must consult certain AUC using a qualified clinical decision support mechanism (CDSM).

The rule was delayed after industry stakeholders expressed concerns over implementation given the complexity of the AUC program. “Some facilities are going to continue with implementation, but this extension gives them more time to work out any issue they are going to encounter,” says Luann Culbreth, MBA, RT, FACHE, director, radiology and cardiovascular services at HealthTrust.

The rule allows for an educational and operations testing period of one year that will begin on Jan. 1, 2020. This testing period is helpful for providers since it allows participation while avoiding claims denials, according to the Association for Medical Imaging Management (AHRA). During this period, the CMS will continue to pay claims whether or not the correct AUC information is included. However, by January 2021, the CMS will begin denying or auditing incorrect AUC claims.

The CMS is also moving forward with the voluntary reporting period, which extends from July 2018 through Dec. 31, 2019. “However, the voluntary reporting period is dependent on the ability of the Medicare claims system to accept and process AUC claims that include consultation information,” AHRA says.

The Road to Appropriate Use Criteria

July 1, 2018:

Voluntary period begins for early adopters to start reporting AUC information.

July 2020:

Educational testing period begins, where ordering providers must consult AUC, but no claims will be denied for improper AUC information.

January 2021:

CMS will begin to deny or audit claims with incorrect AUC information.

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