Legislation is pending in the U.S. Senate and House that attempts to resolve implementation problems of the failed 2014 Medicare Appropriate Use Criteria (AUC) Program for advanced diagnostic imaging. ASNC opposes this legislation and needs your help to educate congressional lawmakers about why a separate Medicare AUC Program is the wrong path for ensuring appropriate use of cardiac imaging tests. 

The Radiology Outpatient Ordering Transmission (ROOT) Act (S. 1692/H.R. 5737) would require clinicians who order advanced diagnostic imaging tests to consult AUC using a Clinical Decision Support Mechanism (CDSM) qualified by the Centers for Medicare and Medicaid Services (CMS). The CDSM must be able to submit to  CMS the following:

• Which CDSM was consulted;
• Whether the service ordered would adhere to AUC; and
• The NPI of the ordering professional

The health care professional furnishing the test would need to report the NPI of the ordering clinician on the claim for the service. 

The legislation requires CMS to identify “low-compliant” ordering professionals. The compliance rate of ordering professionals would be calculated using the ratio of the number of claims for orders during a specified period for which a CDSM was used to consult AUC and the total number of advanced imaging test orders, with exceptions for excluded orders. 

Among orders that would be excluded include: emergency services, inpatient services, cases of significant hardship (e.g., professionals who practice in a rural area without sufficient internet access); imaging services ordered as part of a clinical trial; professionals in small practices (15 or fewer ordering professionals) or in health professional shortage areas; and imaging used for preventive services (e.g., mammography, CT for lung cancer screening, and CT colonography).

Even with these changes to the AUC Program, ASNC’s concerns persist. First, the proposed program would require ordering clinicians to use a CMS-qualified CDSM. ASNC’s position is that ordering clinicians should be able to use any method to consult AUC, especially since a CDSM could restrict which AUC a clinician can consult. During the voluntary testing period of the failed AUC Program mandate, the CDSMs put in place by hospitals and health systems oftentimes excluded the cardiology-developed AUC. 

In addition to a more flexible approach to how physicians consult AUC, ASNC also holds the position that AUC consultation should be part of broader quality improvement reforms, rather than a stand-alone program. 

ASNC members are encouraged to contact their members of Congress and ask them to OPPOSE the ROOT Act.