News | Clinical Decision Support | November 05, 2015

CMS Delaying Clinical Decision Support Implementation Deadline

Agency acknowledges that required appropriate use criteria mechanisms will likely not be in place in time for January 2017

CDS, clinical decision support, CMS, implementation delay, Greg Freiherr

November 5, 2015 — ITN consultant Greg Freiherr has been covering clinical decision support (CDS) through a series of blog posts this month, examining the benefits and challenges of the movement toward evidence-based medicine. The following is an update on the topic:

The Centers for Medicare and Medicaid Services (CMS) announced today that it will delay the Jan. 1, 2017, deadline for ordering professionals to be consulting CDS and appropriate use criteria (AUC) mechanisms for radiology exams. CMS said the decision was made in recognition that many of the described mechanisms will likely not be in place by the beginning of 2017, but that the following summer is a more realistic target.

The original deadline was set forth in section 218(b) of the Protecting Access to Medicare Act (PAMA) of 2014, meant to encourage providers to make evidence-based decisions on imaging exams and reduce the number of inappropriate exams patients are exposed to. This would also help drive healthcare costs down as part of the industry-wide shift from a volume-based to a value-based payment model.

While supporting the idea in theory, numerous individuals and organizations have raised concerns about the wisdom of making such a dramatic change in procedure so quickly. Following a request for comments this past July, Sheila M. Sferrella, CRA, FAHRA, senior vice president, Regents Health Resources, Franklin, Tenn., addressed several of these concerns through a post to the Association of Medical Imaging Management’s (AHRA) website, stating, “No one in radiology wants to perform a test that is not appropriate,” said Sferrella, who is also chair of the AHRA Regulatory Affairs Committee. “The question is do we do this in a way that is thoughtful, deliberative and less likely to have errors? Or, do we rush pell mell ahead and get to the finish line only to discover that we did a shoddy job and have lots of mistakes to fix or try to get past?”

Sferrella and AHRA believe that CMS needs to determine clearer definitions and processes before CDS implementation can be successfully undertaken. Once those elements are in place, AHRA predicts full implementation and compliance will take 12–18 months.  

Visit Greg Freiherr’s blog series here for more information on clinical decision support.

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