July 13, 2015 - The American College of Radiology (ACR) applauds the Centers for Medicare & Medicaid Services (CMS) for proposing steps toward a more evidence-base imaging policy in the Medicare Physician Fee Schedule proposed rule. The ACR is particularly encouraged that CMS is considering proposed actions with ACR input regarding appropriate use criteria (AUC) and clinical decision support (CDS) development and digital practice expense inputs regarding the transition from film to digital radiology.
CMS is beginning the implementation process Congress mandated last year in the ACR-backed Protecting Access to Medicare Act (PAMA). The law requires that providers consult AUC when ordering advanced imaging studies for Medicare patients. CMS is laying out its broad game plan to put this mandate into practice by the Jan. 1, 2017 deadline.
The agency is proposing that this program can only be successful if implemented broadly, with comprehensive libraries of AUC that meet strenuous evidence and clinically appropriate thresholds. The agency reiterates the legislative requirement that all qualified AUC must be accessible to ordering physicians in a no-cost format and be integrated seamlessly into available electronic medical records (EMRs). CMS is asking for input from all stakeholders on meeting the appropriate definition that these AUC are developed by physicians and their professional organizations - hopefully not third-party insurance agents.
ACR, its members and the Radiology Business Management Association (RBMA) also provided CMS a great deal of feedback and documentation regarding its 2015 MPFS rule to use desktop computers as a proxy for picture archiving and communication systems (PACS) as the film to digital radiology evolution advances. This move reduced reimbursement for many imaging exams in FY 2015. CMS is now proposing to double the price/PE allowance for the PACS workstation to $5,557 from the current price of $2,501 since the latter price was based on the proxy item and the former based on ACR member-submitted invoices. This proposal, when finalized, should result in increased reimbursement for many radiology exams and procedures in FY 2016.
The ACR provided a preliminary summary of radiology provisions in the FY 2016 MPFS proposed rule on July 8. The college will provide more detailed analysis of the MPFS in the weeks ahead.
For more information: www.acr.org
August 18, 2026 
