Everyone in healthcare knows the importance of getting paid for services, and outpatient diagnostic imaging procedures are no exception. Beginning January 1, 2019, providers must comply with imaging appropriate use criteria (IAUC) — as outlined by the Centers for Medicare and Medicaid Services (CMS) in accordance with the Protecting Access to Medicare Act (PAMA) of 2014 — when ordering Medicare Part B outpatient advanced diagnostic imaging services, such as CT, MRI, and nuclear medicine including PET scans.
Although you have an extra year to prepare your EHR for compliance, it’s never too early to familiarize yourself with the requirements for meeting this regulation, especially since providers can still choose to use IAUC as a submission item for the Merit-Based Incentive Payment System (MIPS). Here’s some initial steps to keep in mind:1. Determine how your hospital is going to meet this regulation.
CMS has determined that only Provider Led Entities may publish IAUC. To identify whether an advanced diagnostic imaging service is appropriate, the procedure must be scored by a certified decision support product. Some IT vendors offer this functionality within their software, but others, like MEDITECH, have decided to collaborate with an outside company such as the National Decision Support Company (NDSC) to streamline the licensing and activation of features required for compliance.2. Decide how you will prepare your EHR to submit procedures for scoring.
Regardless of how your certified decision support product scores imaging procedures, some data preparation is likely to be required. Implementation checklists are helpful to outline steps for capturing the appropriate information when placing orders and to best prepare your data for scoring. Determining timeframes for accomplishing tasks is also important. You may need to familiarize yourself with export instructions and API credentialing. MEDITECH customers, for example, must run a utility to map their procedures to determine which clinical impressions should appear based on diagnosis, before submitting them to NDSC’s CareSelect ImagingTM product for scoring. Once mapped, time should be allocated for testing the submission process.3. Evaluate your current workflow to determine if changes are required to meet compliance.
Many healthcare providers are accustomed to working collaboratively with nurses to place orders and prepare procedures for their patients. This regulation states that ordering professionals must consult appropriate use criteria. Therefore, it may be necessary to adjust your workflow to accommodate for this guideline in the event that orders are placed by someone other than who is submitting the ID number for IAUC approval. Be sure to allow for adequate time to educate and train staff regarding new workflows.
MEDITECH customers can reference MEDITECH’s IAUC Resource page for implementation details, as well as product-based workflow guides and education and training. Additional information about this regulation, including how it relates to inpatient imaging procedures, claims-related information, and common terms are also available. For clarification or additional information, please contact your Order Entry or Radiology support specialist.
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