Clinical Decision Support (CDS) software has long been a part of the medical community, providing vital tools to assist physicians and their teams in making informative, swift decisions. From diagnostic support to patient data reports, CDS has aided physicians in all specialties.
New proposed Federal rulings for Medicare are about to change requirements for use of CDS systems. According to Federal Register Proposed Rule CMS-1676-P, beginning January 1, 2019, advanced outpatient imaging tests for Medicare patients must first consult an approved CDS system. If the system is not consulted, the imaging test will not be approved for billing.
This new rule aims to reduce regulatory burdens and assist physicians in selecting the imaging test that would best improve health outcomes for patients, based on the unique needs of those patients. It also looks to aid furnishing providers, such as radiologists, by providing consultation information and ensuring that patients are getting appropriate imaging.
Ed Swager, CEO of Radiologic Associates of Fredericksburg, adds that the new rule will not in itself prevent a provider from ordering tests, even if the applicability or ranking of the test is deemed low. “The ordering provider, in theory, would order high-end imaging like they always do. Under the new rule, the provider would let the CDS software know the patient’s clinical condition and let the software rate the appropriateness of the study based on the clinical condition by giving the test a ranking of high to low. Based on the proposed rules, in time, providers ordering studies scoring with low relevance would be required to obtain preauthorization from Medicare.”
The release of the proposed rule was originally slated for the beginning of 2018, but has now been pushed back to January 1, 2019. “Ever since the proposed rule was introduced several years ago, Radiologic Associates of Fredericksburg has been preparing for the CDS change. With the date of implementation now January 1, 2019, this will give vendors and providers another 12 months to have the appropriate software, as well as implement the new codes and modifiers from Medicare.”
According to Mr. Swager, the first year of the ruling will be mostly educational, allowing both the physicians and the CMS to implement the new software and see how it truly works. “The first year is an educational and testing year, which will give everyone more time to meet the complexities and changes that are coming.”
Radiologic Associates of Fredericksburg and the Mary Washington Healthcare system have been working to ensure that the transition is seamless for both physicians and patients. By collaborating with National Decision Support (NDS) to update CDS software, their goal is to make certain every provider’s system is up to date and ready for the change. “If an ordering provider does not have the software, then we’ll look to identify some web-based tool for them.”
For patients in the region who ask if this ruling could affect their medical imaging tests, Radiologic Associates of Fredericksburg has ensured appropriate imaging tests for years. “Our group has historically reviewed Medicare claims and Medicare procedures to make sure that they’re appropriate studies,” said Swager. “We’ve already been doing that part of the process.”
Providers with questions should call Radiologic Associates of Fredericksburg at (540) 361-1000. Radiologic Associates of Fredericksburg will continue to update providers as the changes are finalized.