ACR submits comments supporting Patients Over Paperwork initiative

The American College of Radiology (ACR) submitted comments Aug. 12 to CMS indicating its support for reducing administrative burden through the Patients over Paperwork initiative.

Under the umbrella of CMS’s broader initiative is the Protecting Access to Medicare Act (PAMA), which mandates ordering providers consult an appropriate use criteria (AUC) clinical decision support (CDS) tool when ordering advanced diagnostic imaging for Medicare patients. The ACR praised the legislation—which begins Jan. 1, 2020, as an educational year with no reimbursement penalties—noting it does not force ordering providers to adhere to AUC recommendations.

“Unlike time consuming prior authorization (PA) programs that can ultimately delay and even overrule a physician’s medical judgement and deny a patient from receiving a procedure, there is no ‘hard stop’ to the AUC ordering process,” the document read.

“PA programs remain a true threat to both ordering and referring physicians alike as it presents considerable administrative costs and operates in a non-transparent manner.”

Physicians who “consistently” override AUC recommendations will face an “outlier policy” which CMS has not yet defined. The ACR suggested such outliers will likely fall in numbers once ordering physicians are familiar with the CDS process.

“ACR supports CMS’ Patients over Paperwork initiative and strongly believes that the Appropriate Use Criteria (AUC) program will play an important role with the broader Patients over Paperwork initiative,” according to the document.

“We encourage CMS to continue to work with physicians and their professional societies to reduce administrative burden, especially when it comes to prior authorization.”