ACR letter to CMS addresses AUC, lung cancer screening

The American College of Radiology (ACR) published a letter to CMS acting administrator Andy Slavitt before the holidays, summarizing its thoughts on 14 different issues related to the imaging industry.

Through the letter, which was signed by William T. Thorwarth, Jr., MD, ACR CEO, the organization commented on CMS decisions it agreed with and some it did not. Topics included appropriate use criteria (AUC), lung cancer screening, and relative value unit (RVU) valuation.

The ACR began its letter by examining the current state of AUC. With its Medicare Physician Fee Schedule (MPFS) final rule, released in October 2015, CMS postponed the original Jan. 1, 2017, deadline for physicians to start using clinical decision support (CDS) based on AUC when ordering advanced imaging studies. But the ACR was prepared to meet that deadline, the organization points out, and it could help others with compliance as well.

“The ACR is prepared to execute its AUC program under that schedule and can assist CMS in achieving the implementation date mandated in the law,” Thorwarth wrote in the letter. “The ACR’s AUC, together with a delivery mechanism capable to house multiple AUC have already been integrated with major electronic health records (EHRs) and have been widely deployed in the market.”

The ACR also requested confirmation of a specific phrase: provider-led entities (PLE). Originally, national professional medical specialty societies and PLEs were viewed as two completely separate distinctions. In the MPFS final rule, however, CMS seemed to categorize national professional medical specialty societies as PLEs.

This definition has a big impact on AUC, the ACR explained, and clarification is required.

The ACR letter also suggested that future guidance on the topic would not need to wait for the 2017 MPFS proposed rule.

“Although the ACR agrees with the agency that the MPFS rulemaking process is the most appropriate and administratively feasible implementation vehicle, we also believe that subregulatory guidance can be used to complement the rulemaking process in order to meet the statutory deadlines,” Thorwarth wrote in the letter.

In early November, a statement from the ACR addressed this same topic, but in less detail.

The letter also addresses lung cancer screening, specifically CMS’ decision—again, in the MPFS final rule—to value low dose computed tomography at 1.02 RVU, the same level as non-contrast chest CT.

The ACR repeats its belief that these two services should not be viewed as equal, also pointing out errors it believes it identified in the CMS’ calculations.

In addition, the ACR uses its letter to request clarification on specific CPT codes and requests a Refinement Panel review of other code changes made by CMS.

The full 18-page letter can be read in full on the ACR’s website.