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!
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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
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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
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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."
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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)
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