Practice Management

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  • 1.  AUC CDS

    Posted 03-08-2021 14:05
    Question: if a radiology group performs the AUC-CDS consultation, is this considered a fraudulent/false claim? I know CMS has clarified who may perform the required AUC consultation using a qCDSM when the consultation is not performed personally by the ordering professional whose NPI is listed on the order, i.e. the consultation may be performed by clinical staff working under the direction of the ordering professional. And that CMS has adopted the AMA's definition of clinical staff. However, I was recently asked about the above being a false claim and have not seen anything in writing about fraud.

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

    Posted 03-08-2021 14:23

    Putting aside the obvious that such activity likely is not an authorized consultation, the most relevant guidance would be the various OIG advisory opinions describing how diagnostic imaging suppliers can perform prior authorizations with payers for advanced  imaging services. The OIG signed off on such activity, provided:

     

    1.       The role of the imaging center was fully transparent that it was the imaging center and not the ordering physician that obtained the prior authorization, and;

    2.       The prior authorization support is offered to every referring physician and not dependent on the volume or value referred from those physicians.

     

     

    Thomas W. Greeson

    703.517.0495 (cell)

    tgreeson@reedsmith.com

    Pronouns: He/Him/His

     

    Reed Smith LLP

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    McLean, Virginia 22102-5979

    Office Telephone: 703 641 4242

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