July 14, 2017 — In a series of proposed rule changes to the Medicare Physician Fee Schedule (MPFS) released July 13, the Centers for Medicare and Medicaid Services (CMS) pushed back the start date for when providers will be required to consult clinical decision support (CDS) for advanced diagnostic imaging to 2019. CMS indicated the first year would be considered an “educational and operational testing year,” meaning claims would still be paid on advanced diagnostic imaging services that do not indicate appropriate use criteria (AUC) were consulted.
The proposed rule change marks the second time that required CDS reporting has been delayed. The rule was first included in the final Stage 3 Meaningful Use guidelines for electronic health records (EHRs) and was slated to go into effect Jan. 1, 2017. At the time, however, there were no federal guidelines for development of CDS software, and vendors said it would take at least a year to create and implement the software once guidelines were available. As a result, the date was pushed back to Jan. 1, 2018.
The proposed rule also notes that CMS is expanding the list of qualified provider-led entities (PLEs) that are permitted to develop AUC and clinical decision support tools for various subspecialties. The list of qualified provider-led entities as of June 2017 includes:
- The American College of Radiology (ACR);
- The Society for Nuclear Medicine and Molecular Imaging (SNMMI);
- The American College of Cardiology Foundation;
- Banner University Medical Group-Tucson University of Arizona;
- CDI Quality Institute;
- Cedars-Sinai Health System;
- Intermountain Healthcare;
- Massachusetts General Hospital Department of Radiology;
- Medical Guidelines Institute;
- Memorial Sloan Kettering Cancer Center;
- National Comprehensive Cancer Network;
- Sage Evidence-based Medicine & Practice Institute;
- University of California Medical Campuses;
- University of Utah Health;
- University of Washington School of Medicine;
- Virginia Mason Medical Center; and
- Weill Cornell Medicine Physicians Organization.
CMS is seeking comment from stakeholders on whether CDS implementation should be delayed beyond 2019 and how long the testing period should last (if providers believe it should be longer than a year).
Use of clinical decision support tools will also help providers qualify for incentives under the Merit-Based Incentive Payment System (MIPS), part of CMS’ new Quality Payment Program (QPP) to encourage the shift toward value-based care. The QPP — which includes MIPS and the Alternative Payment Models (APM) track — will replace the Physician Quality Reporting System (PQRS), enacted in 2011, as the primary mechanism to incentivize providers to practice and report on high-quality patient care. With the initial MIPS reporting period underway this year, CMS announced several adjustments for the final PQRS reporting period in the July 13 proposed rule:
Individual eligible professionals and group practices who did not satisfactorily report data on quality measures in 2016 are subject to a downward payment adjustment of 2 percent in 2018 to their MPFS services;
The agency also proposed changing the number of required reporting measures from nine to six across the three National Quality Strategy domains of the PQRS. This change is meant to better align PQRS reporting requirements with MIPS data submission requirements for the quality performance category.
Read the article “CMS to Require Appropriate Use Criteria Documentation for Medical Imaging Orders”
Watch the VIDEO “Clinical Decision Support Requirements for Cardiac Imaging”
For more information: www.cms.gov
February 17, 2026 
