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qCDSM

National Decision Support Company’s Clinical Decision Support Mechanism has been Fully Qualified by the Centers for Medicare & Medicaid Services

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NDSC’s Mechanism, known as CareSelect Imaging™/ACR Select™, has been Qualified for Use with the Protecting Access to Medicare Act (PAMA) and the Medicare Access and CHIP Reauthorization Act (MACRA)

Madison, WI (July 18, 2017) – National Decision Support Company announces the full qualification of its CareSelect™ Platform as a Qualified Clinical Decision Support Mechanism (qCDSM) by the Centers for Medicare and Medicaid Services (CMS) for compliance with the Appropriate Use Criteria (AUC) provisions under PAMA and MACRA.

On June 20th, 2017, CMS released the MACRA proposed rule and specified that MIPS eligible clinicians will receive credit in the practice improvement category. When implemented within Certified Electronic Health Record Technology (CEHRT) clinicians will receive credit towards their Advancing Care Information (ACI) performance score for consultation of the CDSM across all advanced diagnostic imaging services.

On July 13, 2017, CMS released the CY2018 Medicare Physician Fee Schedule (MPFS) proposed rule, including an updated list of Provider Led Entities and a list of qualified CDSMs. CDSM’s can be approved for two levels of qualification – preliminary or full. Preliminary qualification indicates that the mechanism does not yet meet the requirements as outlined by CMS. Full qualification indicates that the mechanism does meet the requirements as outlined by CMS and can be used for compliance with PAMA and MACRA. NDSC’s CareSelect qCDSM meets all the requirements as outlined by CMS for full qualification.

In the CY2018 MPFS Proposed Rule, CMS reiterated and clarified that consultation of a qCDSM is required for all applicable advanced diagnostic imaging exams and provided important information about the required consultation data for claims to receive payment.

“What’s still missing from this program is how CMS intends to flag ordering providers as outliers. Providers need to be aware that both the adherence to the Appropriate Use Criteria (AUC), as well as the applicability of the AUC to their scope of practice are both opportunities for CMS to flag providers as outliers,” said Robert Cooke, Vice President of Marketing at NDSC. “A comprehensive consultation requirement translates to comprehensive measurement. qCDSMs must report not only on adherence to AUC, but also applicability of the AUC to their scope of practice. If an organization implements a CDSM that does not deliver AUC that cover the providers scope of practice, there is a risk that many consultations will not yield applicable AUC, and thus increase the likelihood that these providers will be subject to the additional burden of prior-authorization.”

CareSelect Imaging delivers a comprehensive and growing set of structured indications and AUC from five qPLE including the American College of Radiology (ACR Select™), the American College of Cardiology, the National Comprehensive Cancer Network® and the Society of Nuclear Medicine and Molecular Imaging. In addition, NDSC is collaborating with healthcare organizations that are qualified by CMS as qPLEs to utilize NDSC’s CareSelect Platform to deliver their AUC. These organizations will author their own AUC for delivery through the CareSelect CDSM.

These clinical guidelines are rationalized into NDSC’s CareSelect Platform to enable full compliance the AUC provisions of PAMA and MACRA. NDSC’s comprehensive clinical coverage ensures that providers can always find the correct clinical scenario for every advanced imaging exam including all Priority Clinical Areas (PCAs). This ensures that a payable claim is generated for every advanced imaging exam.

“The reporting requirements outlined in rulemaking are a subset of the data that the qCDSM must record. Combined with the requirement that CDSM must store data for 6 years, we expect that the data recorded in the mechanism will be subject to audit,” said Cooke. “Qualification indicates that the technology meets some minimum standard, including AUC coverage. This minimum standard does not consider the scope of practice for a provider. NDSC is engaged with over 500 health systems representing over 2,500 discrete facilities, delivering tight integrations with almost all major EMR platforms.  When considering a strategy for compliance, ensuring that AUC covering the full scope of practice is a  critical decision point for caregivers when implementing a qCDSM.”

The implementation of CareSelect Imaging represents an opportunity for the healthcare community to implement programs that avoid prior authorization for not only Medicare Services, but to leverage advanced features of the CareSelect Platform to implement strategies that automate and streamline the existing prior authorization process across all payers.

For more information on NDSC’s CareSelect Imaging Solution please visit www.nationaldecisionsupport.com/imaging

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About National Decision Support Company
National Decision Support Company delivers enterprise-wide Clinical Decision Support solutions that enable more appropriate care, improve population health, and reduce cost. NDSC’s CareSelect Imaging™ converts published guidelines into actionable criteria that is delivered directly into the EMR workflow. Criteria covers adult and pediatric patient populations featuring guidelines sourced directly from the Society for Pediatric Radiology. For more information, visit www.nationaldecisionsupport.com.

About CareSelect Imaging™
CareSelect Imaging expands on NDSC’s foundational ACR Select™ solution to deliver a comprehensive range of Appropriate Use Criteria (AUC) for diagnostic imaging in both adult and pediatric patient populations. AUC is sourced from a growing list of qualified Provider Led Entities (qPLE), including the American College of Radiology, the American College of Cardiology, the National Comprehensive Cancer Network® and the Society of Nuclear Medicine and Molecular Imaging to ensure compliance with the Protecting Access to Medicare Act of 2014 (PAMA) and the Medicare Access and CHIP Reauthorization Act (MACRA).

Media Contact:
Bob Cooke –  VP of Marketing, NDSC
rcooke@nationaldecisionsupport.com
203.918.5085

 

PAMA and MACRA – A Surprising Twist

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In the recent proposed rule for year two of The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), the Centers for Medicare and Medicaid Services (CMS) have introduced a surprising twist – linking the Protecting Access to Medicare Act (PAMA) to MACRA.

Tucked away on page 178 of the proposed rule is a new improvement activity linked to the Advancing Care Performance Category. This improvement activity allows organizations who have implemented a qualified Clinical Decision Support Mechanism (qCDSM) to receive credit in this category:

A MIPS eligible clinician would attest that they are consulting specified applicable appropriate use criteria (AUC) through a qualified clinical decision support mechanism for all advanced diagnostic imaging services ordered. This activity is for clinicians that are early adopters of the Medicare AUC program (e.g., 2018 performance year) and for clinicians that begin the program in future years as will be required by CFR §414.94 (authorized by the Protecting Access to Medicare Act of 2014). Qualified mechanisms will be able to provide a report to the ordering clinician that can be used to assess patterns of image-ordering and improve upon those patterns to ensure that patients are receiving the most appropriate imaging for their individual condition.

This development provides some tantalizing useful and important insight into the PAMA regulatory process:

  1. Providers must attest to consulting the qCDSM across all advanced imaging. We recognize that CMS has yet to publish the anticipated 3rd MPFS proposed rule; however this should clear up any mystery about limiting consultations to just the 8 Priority Clinical Areas (PCA). NDSC’s interpretation has always been that all advanced imaging orders require a consultation of applicable AUC, not just the PCAs.
  2. Our interpretation is that the timing for PAMA will now align with the first MACRA payment adjustment. CMS is rewarding providers who have or are currently adopting AUC based on CMS’ guidance that starting Jan 1 2018, claims for Medicare Part B advanced imaging services require evidence of a qCDSM consultation.

In short, the country’s largest payer now requires consultation with a qCDSM across all advanced imaging services. This is certain to have implications for traditional utilization management approaches that rely on prior authorization through third parties.

Useful Links: MACRA Proposed Rule Fact Sheet