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Important Change Regarding Format for RADPAC Events at 2013 AMCLC RADPAC will again host its RADPAC Annual Reception on Tuesday, May 7th  from 6:00pm to 7:00pm at the Washington Hilton. This reception is open to all AMCLC attendees.   And, like last year, there will be a RADPAC Thank You Dinner. This year's event will be at an off-site location.  Transportation will be provided.  It will be a fun, scenic evening that shows you Washington, DC in a way you may have never seen before.  Like last year, thie event will be available ONLY for those ACRA members who have contributed (or pledged) $1,000 in the 2013 calendar year by no later than Friday, April 19.  To contribute now you can go to www.radpac.org and click on the Contribute Online button on the right.  In addition, in order to be recognized on signage at the meeting as a contributor RADPAC will need to have your contribution pledged or given prior to April 11, 2013.   Please note that contributions made at the AMCLC will NOT be counted for invitational purposes to this exclusive RADPAC Thank You Dinner.  As an ACRA member, if you have a record of giving on a periodic basis to RADPAC and if you choose such a method again for 2013 you will qualify for the Thank You Dinner if your contribution totals $1,000 or more during this calendar year.   Those who pledge/contribute at the $1,000 level or above will receive two tickets for this event - one for themselves and one for a guest.  These tickets are non-transferable.   For Information on this special event, please contact Heather Kaiser at the ACRA office at 1-800-227-5463, ext. 4543 or by email to hkaiser@acr.org.

Multiple Procedure Payment Reduction and H.R. 846/S. 623, the Diagnostic Imaging Services Access Protection Act Application of an MPPR to the professional component of diagnostic imaging services performed on the same patient on the same day is an arbitrary and imprecise tool to control Medicare spending. Imposition of this policy will also make it difficult for radiologists to keep free-standing imaging facilities open for business, thus threatening patient access to important diagnostic imaging services.  LEARN MORE...

 

Dear ACR Councilor/Alternate Councilor:

As part of the AMCLC Hill Day on May 8, participants will be advocating for two issues on behalf of the ACR; the repeal of the multiple procedure payment reduction (MPPR) and the adoption of an imaging utilization management policy mandating the use of clinical decision support tools by ordering physicians.

Since many of you are already familiar with the MPPR issue from advocating for its repeal last year, I wanted to take this opportunity to provide an overview of the imaging utilization management policy the College will be pursuing so councilors can familiarize themselves with the policy prior to the Hill Day Preparation session on Monday May 6th. To this end, our Government Relations staff has provided two documents to brief you on this bold policy that is intended to steer federal lawmakers and regulators away from its previous philosophy of implementing reimbursement cuts to reduce imaging utilization, and instead point them towards a more focused, efficient and patient-centered option of utilization management where the value of the radiologist is emphasized.

I ask that you please review the policies below and the FAQs prior to attending the AMCLC. In the meantime, if you have questions, comments, or concerns regarding the College’s imaging utilization management policy, please do not hesitate to contact our Government Relations Department at govrelations@acr.org.

 

Stop Endless Cuts to Medical Imaging and Enact Meaningful Imaging Utilization Management Policies

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Issue Background: Since 2006, diagnostic imaging has been cut 12 different times either through legislation or regulation. The most recent cut was enacted as part of the American Taxpayer Relief Act of 2012 and, as most of the cuts associated with imaging, was arbitrary and not based on detailed data analysis. This continued assault on diagnostic imaging undermines the specialty and the cumulative effects of these cuts will ultimately affect patient access to care through the continued reduction in facility availability through reduced hours or facility closure.

Now, as Congress begins to shift its focus to address such issues as entitlement reform and SGR reform, the membership of the ACR is steadfastly opposed to being further singled-out for unsubstantiated cuts to diagnostic imaging reimbursement. Instead, the College believes Congress should develop far-reaching and sustainable policies that guide physicians to the correct ordering and utilization of imaging services, thus allowing patients continued access to the technologies that have improved the lives of so many and has changed the landscape of modern medicine irrefutably. In an effort to move Congress away from just implementing further misguided cuts to imaging reimbursement, the College proposes an imaging utilization management policy employing computerized decision support (CDS) tools. This policy will reduce the number of incorrect or inappropriate exams, better educate ordering physicians as to what imaging tests are the most appropriate for their patients and provide meaningful data to better determine the best use of imaging resources in the future.

Policy Fundamentals: Imaging utilization management legislation would require ordering physicians participating in the Medicare program to consult a CDS system designated by the Secretary of HHS prior to ordering a study. The CDS system would be accessed through a Centers for Medicare and Medicaid Services (CMS) portal provided by the CDS vendor(s) to the federal government and the ordering physician at no cost. Consultation of the CDS by the ordering physician would be verified by the generation of a decision support number (DSN) that would be included with the imaging exam order. The rendering physician (the physician interpreting the imaging exam) would not receive his professional component (PC) payment and the facility (depending on site of service) would not receive its technical component (TC) or hospital outpatient prospective payment system (HOPPS) payment unless a DSN is included with the imaging claim submitted to Medicare. Furthermore, CDS systems could be connected to data registries, which in turn would satisfy PQRS requirements for both the ordering and rendering physician.

Utilizing CDS tools that incorporate national physician association-developed appropriateness guidelines, such as the American College of Radiology's Appropriateness Criteria (AC), allow ordering physicians to avoid the timely, costly and often controversial burden of consulting a radiology benefit manager (RBM) or another type of preauthorization process. In addition, ordering physicians will be able to provide real-time feedback for their patients with regard to what is the most appropriate exam for their condition. When embedded in CDS tools, AC can guide and educate the ordering physician to the correct diagnostic imaging study for their patients, as well as play a significant role in ensuring that only the necessary diagnostic exam is ordered. In many facilities and states where CDS has been implemented, estimates have suggested that significant savings can be achieved. It is expected that similar savings can be extrapolated by the Congressional Budget Office (CBO).

Policy Recommendation: Federal policy makers must enact an imaging utilization policy that emphasizes the use of medical specialty society appropriateness criteria. Such utilization management policies are ideal for inclusion in a forthcoming entitlement reform bill or legislation addressing the flawed sustainable growth rate (SGR) formula. Should you have any additional questions, please contact Josh Cooper (Jcooper@acr.org), Senior Director, Government Relations, Rebecca Spangler (Rspangler@acr.org), Director, Congressional Affairs, or Chris Sherin (Csherin@acr.org), Director, Congressional Affairs.

 

 

ACR Utilization Management Policy - Frequently Asked Questions

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Introduction

The American College of Radiology (ACR) is consistently regarded as the leader in the development of imaging appropriateness criteria, or comprehensive evidence-based guidelines which assist referring physicians and other providers in making the correct, most efficacious imaging or treatment decision for patients. Developed by expert panels in diagnostic imaging, interventional radiology, radiation oncology, as well as representatives from other medical specialties, ACR Appropriateness Criteria ® embodies the best, most robust guidelines for selecting diagnostic imaging and interventional procedures. In fact, the February 2013 edition of the ACR Appropriateness Criteria ® covers 186 topics and over 900 variants.

To try and move Congress from just implementing further misguided cuts to imaging reimbursement, the College proposes an imaging utilization management policy which employs computerized decision support (CDS) tools. This policy will reduce the number of incorrect or inappropriate exams, better educate ordering physicians as to what imaging tests are the most appropriate for their patients and provide meaningful data to better determine the best use of imaging resources in the future.

Answers to a variety of frequently asked questions related to the specifics of the College’s utilization management policy are found below:

Q1. What Does This Utilization Management Policy Do?

A1. The College’s utilization management legislation seeks to require referring physicians to consult web-based CDS tools that incorporate ACR Appropriateness Criteria ® whenever they intend to order advanced diagnostic imaging services for patients. More specifically, effective January 1, 2015, ordering physicians will register with a Medicare approved web-based, CDS system that is provided to the Centers for Medicare and Medicaid Service (CMS) at no cost to the government or the referring physician. Mandating the use of web-based CDS tools is designed to eliminate instances of inappropriate imaging of patients.

Legislation would require ordering physicians participating in the Medicare program to consult a CDS system designated by the Secretary of HHS. The CDS system would be accessed through a CMS portal provided by the CDS vendor(s) to the federal government and the ordering physician at no cost. Ordering physicians would be required to consult the CDS tool prior to ordering a study. Consultation of the CDS by the ordering physician would be verified by the generation of a decision support number (DSN) that would be included with the imaging exam order. The rendering physician (the physician interpreting the imaging exam) would not receive his professional component (PC) payment and the facility (depending on site of service) would not receive its technical component (TC) or hospital outpatient prospective payment system (HOPPS) payment unless a DSN is included with the imaging claim submitted to Medicare.

In addition to eliminating inappropriate diagnostic imaging services, physicians who comply with this utilization management policy will also satisfy the reporting requirements as outlined in the Physician Quality Reporting System (PQRS), as well as the clinical and quality measures contained within the Health Information Technology for Economic and Clinical Health (HITEC) Act (commonly referred to as EHR “meaningful use” legislation) and Value Based Payment modifier.

Q2. Why is ACR Pursuing Utilization Management Policies? Why Should ACR Members Support Utilization Management Policies?

A2. The health care delivery system in the United States is undergoing a dramatic transformation and the specialty of radiology must continue to evolve to meet the changing demands. For example, the implementation of the Patient Protection and Affordable Care Act (PPACA) increased the importance of coordinated care, instituted policies that reward greater physician interaction with patients, as well as began rewarding the quality of care delivered rather than the quantity of services. Federal health care reform is committed to moving physicians from the traditional fee-for-service system of payment.

Yet even before the passage of PPACA, radiology endured substantial reimbursement cuts implemented both through the legislative and regulatory process. Despite a wide variety of robust data proving that advanced diagnostic imaging is one of the slowest growing components of Medicare, the unfortunate reality is that, since 2006, radiology reimbursement has been reduced 12 different times either through federal legislation or regulation.

Imposition of a utilization management policy centering on widespread use of appropriateness criteria will address many of the issues associated with the various threats facing radiology. Expanded use of appropriateness criteria fosters greater interaction between radiologists and other physicians, thereby elevating the role of specialty within coordinated care models. Most importantly, since widespread use of appropriateness criteria will undoubtedly lead to the reduction of inappropriate diagnostic imaging services, any corresponding savings associated with the implementation of a utilization management policy can be offered to federal policymakers as an alternative to arbitrary, piecemeal cuts to radiology reimbursement and/or Radiology Benefit Manager (RBM) preauthorization programs. Expanded use of ACR Appropriateness Criteria ® is a concerted effort to shield radiologists from continued cuts in Medicare reimbursement which undermine the specialty and threaten patient access to important, life-saving access to advanced diagnostic imaging services. Lastly, radiologists would also benefit from utilization management registries satisfying reporting requirements associated with other health care policies already in operation, including PQRS.

Q3. Why Should Referring Physicians Support This Policy?

A3. ACR anticipates support from the referring physician community due to the fact that CDS products are far more effective and less burdensome than the use of third-party Radiology Benefit Managers (RBMs). Web-based imaging CDS tools educate referring physicians in real-time which facilitates faster treatment of patients. In addition, the fact that the CDS tools are provided at no cost to the referring physician and participation in utilization management registries satisfy reporting requirements associated with other health care policies already in operation, such as PQRS, “meaningful use” of electronic health records (EHR), and value based purchasing, is quite enticing to ordering physicians. Plus, efforts to employ imaging CDS tools within the private sector in places like Minnesota and Massachusetts have been very successful.

Preliminary conversations with the American Academy of Family Physicians (AAFP) and the American Medical Association (AMA) were encouraging and ACR will continue to foster greater support for utilization management.

Q4. Will this Utilization Management Policy be Enacted Into Law in the 113th Congress?

A4. Health care and entitlement reform remain a major focus of the 113th Congress. In fact, the House Ways and Means and Energy and Commerce Committee are currently engaged in a major effort to repeal the flawed Sustainable Growth Rate (SGR) with a system that rewards quality of care over quantity of services. Preliminary drafts of the SGR repeal distributed by these key House committees continue to emphasize the use of evidence-based guidelines and the application of CDS within this new physician payment paradigm. The fact that the Congressional Budget Office (CBO) now estimates that the cost of repealing the SGR now costs $138 billion over 10 years, down from approximately $300 billion, has lawmakers bullish on SGR reform. As a result, ACR should have ample opportunities to pursue the inclusion of imaging utilization management policies throughout the 113th Congress.

Q5. Who Should I Contact if I have Additional Questions About Utilization Management Policies?

A5. The appropriate ACR staff contacts for additional questions are Josh Cooper, Senior Director, Government Relations, Rebecca Spangler, Director of Congressional Affairs, and Chris Sherin, Director of Congressional Affairs.