Practice Management

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  • 1.  Appropriate Use Criteria and Clinical Decision Support

    Posted 03-25-2019 16:38

    Dear All,

    There has been a question about if radiologists (furnishing professionals) are required to comply with the Appropriate Use Criteria and Clinical Decision Support Program for services provided in Critical Access Hospitals.  Below is my correspondence with CMS and hoping this is helpful!

    From: Barbara Rubel [mailto:brubel@msnllc.com]
    Sent: Monday, March 11, 2019 9:40 AM
    To: 'joannabaldwin@cms.hhs.gov' <joannabaldwin@cms.hhs.gov>; CMS Imaging AUC <ImagingAUC@cms.hhs.gov>
    Cc: 'sarahfulton@cms.hhs.gov' <sarahfulton@cms.hhs.gov>
    Subject: AUC and Critical Access Hospitals

    Good morning, JoAnna,

    Can you please confirm that a Critical Access Hospital, by definition, is not an "applicable setting" for purposes of Clinical Decision Support and Appropriate Use Criteria?

    And a second question, if I may: is the furnishing radiologist who bills under an "applicable payment system" (MPFS) exempt for services provided to a CAH?

    Thank you so very much for your help!

    *********************************************
    On Mar 12, 2019, at 3:47 PM, CMS Imaging AUC <ImagingAUC@cms.hhs.gov> wrote:

    Dear Barbara,

    Both conditions (applicable setting and applicable payment system) must apply for the advanced diagnostic imaging service to be subject to the Medicare Appropriate Use Criteria Program.  A Critical Access Hospital is not an applicable setting under the program. 

    Sincerely,

    CMS-AUC Team

    ********************************************* 

    From: Barbara Rubel [mailto:brubel@msnllc.com]
    Sent: Tuesday, March 12, 2019 4:47 PM
    To: CMS Imaging AUC <ImagingAUC@cms.hhs.gov>
    Subject: Re: AUC and Critical Access Hospitals

    Thank you! So just to be clear, if a radiologist (furnishing professional) is providing professional interpretations (modifier 26) for a CAH and billing under the MPFS, the radiologist will not be penalized for not providing AUC/CDS information on his/her claim form because the CAH is not an applicable setting and the ordering professionals are not consulting AUC. Correct?

    Sent from my iPhone

    *********************************************
    From CMS (today at 2:46 p.m.)

    "Yes, the program is based on where the imaging service is furnished.  If furnished in a CAH then we would not expect the claim for the professional component to contain AUC consultation information.  We are working to determine how to identify these claims through the Medicare claims processing system to make sure they don't get caught in the system."

     



    ------------------------------
    Barbara Rubel, MBA, FRBMA
    Senior Vice President, Marketing & Client Services
    MSN Healthcare Solutions
    President, FRBMA
    Past President RBMA
    Green Cove Springs FL
    (904) 657-2038 (O)
    (770) 823-3597 (Cell)
    ------------------------------


  • 2.  RE: Appropriate Use Criteria and Clinical Decision Support

    Posted 03-25-2019 16:46

    Thanks, Barbara.  Hopefully, CMS is creating a code for us to apply to the claim that indicates the TC was performed at a CAH. Since PC's bill with the interpretation location, not sure how Medicare will otherwise know.

     

    Theresa King, CPC, CPPM

    Business Process Improvement Manager

    Huron Valley Radiology, P.C.

    5333 McAuley Drive, Suite 6016

    P.O. Box 992

    Ann Arbor, MI 48106

    734.712.8359

    Theresa.king@hvrrad.net

     

    image001.jpg@01D1DB5A.5A848970

     

     

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  • 3.  RE: Appropriate Use Criteria and Clinical Decision Support

    Posted 03-25-2019 16:54

    Huge thank you Barbara as up to now that's not quite the answer they had given!!  As for identifying those, since we have to include the Facility NPI, that should be tied to their CAH designation and they should have no problem identifying these (of course, that would be said tongue-in-cheek as we know how well things work the way we think they should!)

     

    Again thank you for pursuing that and sharing the results – that's great news.

     

    Michelle

     

    Michelle R. Juette, CPC, RCC

    Business Services Manager

    Yakima Valley Radiology

    (509) 895-0402 (direct, voice/mail)

    (509) 248-0733 (secure fax)

    mailto:mjuette@yakrad.com

     






  • 4.  RE: Appropriate Use Criteria and Clinical Decision Support

    Posted 03-25-2019 16:56
    Yee gads, sorry about that -- failed to consider the "interpretation locations" that might fall OUTSIDE of the actual facility -- so yes, hopefully CMS will provide a code &/or modifier that indicates things should pass through under that designation.

    ------------------------------
    Michelle Juette RCC
    Business Services Manager
    Yakima Valley Radiology
    Yakima WA
    (509) 895-0402
    ------------------------------



  • 5.  RE: Appropriate Use Criteria and Clinical Decision Support

    Posted 03-25-2019 17:16

    As always Barbara Rubel is on top of finding these key radiology business answers.  RBMA continues to work with the eOrdering Coalition to seek answers on these specific issues. 

     

     

                                                                                                                                           

    Robert T. Still, FRBMA

    Executive Director

    M:  717.475.6079

    bob.still@rbma.org

     

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