We realize that the Appropriate Use Criteria (AUC) validation mandate of PAMA is not one of those areas that healthcare professionals are likely to be fully familiar with – especially those focused on assisting patients and without the time to research the subject. We’ve therefore provided this frequently asked questions (FAQ) page to help you understand the background and requirements of the AUC mandate. Please note that, while we have summarized some aspects in our own language, we are also providing specific instructions directly from the Centers for Medicare and Medicaid (CMS) web page to ensure complete consistency. If you have questions, we encourage you to reference the CMS AUC website for definitive answers.
PAMA is a broad set of legislation applying to the federally required activities of healthcare professionals and organizations delivering services on behalf of Medicare and Medicaid patients. The law was originally passed in 2014 and has been periodically updated since then. PAMA includes a section that mandates that “ordering professionals” (providers and practitioners) must perform a particular process of validating the use of advanced imaging procedures for Medicare/Medicaid patients against CMS-approved “appropriate use criteria” (AUC) guidelines. If this process is not followed, CMS may potentially deny reimbursement for the procedures and may identify the ordering professional as an outlier subject to future consequences. Currently, all providers are expected to perform AUC validation in a test and educational mode with monitoring and enforcement activities to begin on 1 January 2022 for advanced imaging services that have been ordered without following this process.
Per the CMS website, “The Protecting Access to Medicare Act (PAMA) of 2014, Section 218(b), established a new program to increase the rate of appropriate advanced diagnostic imaging services provided to Medicare beneficiaries…”
“…Under this program, at the time a practitioner orders an advanced diagnostic imaging service for a Medicare beneficiary, he/she, or clinical staff acting under his/her direction, will be required to consult a qualified Clinical Decision Support Mechanism (CDSM). [the LogicNets AUC Solution is a qualified CDSM.] The CDSM provides a determination based on approved guidelines from Provider Led Entities of whether the order adheres to the defined Appropriate Use Criteria (AUC), or if the AUC consulted was not applicable (e.g., no AUC is available to address the patient’s clinical condition). A consultation must take place at the time of the order for imaging services that will be furnished by an imaging center (or furnishing provider). Ultimately, practitioners whose ordering patterns are considered outliers will be subject to prior authorization. Information on outlier methodology and prior authorization is not yet available.”
The CMS defines a CDSM as: “A Clinical Decision Support Mechanism (CDSM) is an interactive, electronic tool for use by clinicians that communicates appropriate use criteria (AUC) information to the user and assists them in making the most appropriate treatment decision for a patient’s specific clinical condition. They may be modules within or available through certified electronic health record (EHR) technology.”
CMS has required that technology vendors developing a CDSM for Medicare providers to use for AUC validation must apply for and be authorized by CMS. A “qCDSM” is a CDSM that has received such qualification from CMS. LogicNets is a qCDSM that is accessed as a cloud service by both interactive users and as an embedded service for EHR systems. CMS assigns a “G-code” for each qCDSM product that is submitted by furnishing providers in order to seek reimbursement. The LogicNets G-Code is G-1019.
CMS has sought to ensure that providers and practitioners ordering advanced imaging services validate appropriateness using Appropriate Use Criteria guidelines that are evidence-based, developed by qualified professionals, and are proven in the field. They have therefore required that the AUC guidelines used for validation under PAMA be developed by “qualified provider-led entities” (qPLEs). The CMS website defines a PLE as “a national professional medical specialty society or other organization that is comprised primarily of providers or practitioners who, either within the organization or outside of the organization, predominantly provide direct patient care. Once a PLE is qualified, the appropriate use criteria (AUC) developed, modified or endorsed by the entity are considered specified applicable AUC.”
The LogicNets qCDSM processes its validations using AUC Guidelines developed and licensed to LogicNets by Intermountain Healhcare and the National Comprehensive Cancer Network (NCCN).
The AUC validation mandate applies to all “advanced imaging services”. Per the CMS website, these generally include:
CMS maintains educational materials on the AUC program that specify by CPT code all procedures that are considered subject to AUC validation.
While all advanced imaging procedures must be processed by a CDSM, the only guidelines that must be made available in the CDSM and which must be used for validation are in the “8 priority clinical areas” specified by CMS.
Advanced imaging orders in the following priority clinical areas must be validated against an AUC guideline provided by a qPLE:
Advanced imaging orders outside of these priority clinical areas must still be processed by the CDSM in order to generate reimbursement codes, but they may be processed without having been checked against a clinical guideline.
AUC validation is only required for patient cases where patient care and reimbursement is being handled under Medicare, Medicaid, or the Children’s Health Insurance Program (CHIP). The process is not relevant or required for imaging services reimbursed under private insurance plans.
Furthermore, emergency patient cases are exempt from the AUC validation requirement. When submitting for reimbursement of emergency Medicare cases, a special HCSPCS modifier is used. Note that, while the CDSM does not need to be referenced to use this code, the LogicNets AUC Solution allows the user to indicate an Emergency patient scenario and it bypasses the processing of the AUC guidelines and generates this code.
The CDSM should provide the following information to document a completed consultation:
The LogicNets AUC Solution provides access to this result information during the consultation process and subsequently in history views and through the AUC Reporting Module.
Starting 2020, all provider organizations processing Medicare and Medicare patient services have been expected to begin the process of educating themselves on their requirements and deployment needs and beginning operational testing. 2020 and 2021 have been designated by CMS as “The EDUCATIONAL AND OPERATIONS TESTING PERIOD.”
According to the CMS AUC web pages, CMS “encourage[s] stakeholders to use this period (CY202 and CY2021] to learn, test and prepare for the AUC program.”
On January 1, 2022, the AUC validation mandate becomes mandatory for all providers and practitioners performing advanced imaging services on behalf of Medicare and Medicare patient cases. At this point, furnishing providers will likely not accept advanced imaging orders without CDSM consultation for AUC outcomes because CMS will no longer reimburse them for these orders. Further, CMS will monitor advanced imaging orders by ordering physicians and potentially will identify them as outliers if they fail to comply with the mandate. Outliers may face “consequences” as yet unspecified by CMS for their lapses in performing AUC validation.