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CMS to require Clinical Decision Support documentation with advanced imaging orders

The Centers for Medicare and Medicaid Services (CMS) will soon require consult of appropriate use criteria (AUC) through a qualified clinical decision support mechanism (CDSM) for advanced imaging orders. Starting this summer, Legacy Health will request documentation of an AUC score from a qualified CDSM with each advanced imaging order placed for Medicare-insured patients. This includes orders for CT, MRI, PET-CT and Nuclear Medicine. Advanced imaging orders received by Legacy that do not meet new documentation requirements will still be accepted, however the ordering practice will receive a fax to ask for an AUC score. 

Starting in 2022, CMS may not reimburse orders that do not meet the new requirements, and Legacy hopes to be fully compliant well before January. Practices that neglect to provide an AUC score come this fall will be contacted directly by Legacy by phone in addition to fax. Prior authorization requirements for practices that are not compliant as well as other penalties from CMS are anticipated but have yet to be defined.  
 
What can you do now? The level of action that providers and their practice’s need to take to be compliant with the new rule varies depending on which Electronic Medical Record (EMR) is in use.  

Practices using Legacy Epic EMR 
Orders for advanced imaging placed through Legacy Epic already meet requirements through the Epic integrated CareSelect tool. No further action is necessary if a structured indication is selected when the order is placed in Legacy Epic. See a tip sheet here.   

Practices using EMRs other than Legacy Epic 
Many EHRs include access to a qualified CDSM that meets the new CMS requirements. Please verify that your practice does have access to a qualified CDSM and that your advanced imaging orders sent to Legacy include an AUC score and the CDSM tool utilized.   

If you find that you do not have access to a qualified CDSM, there are no-cost, open access CDSMs available. One such service is CareSelect Imaging - Open Access. Please register your practice for a qualified CDSM of your choosing and begin submitting the additional AUC score and CDSM tool information on all advanced imaging orders sent to Legacy as soon as possible. 

If you have questions or concerns about the upcoming changes and next steps, please reach out to your Legacy Physician Outreach Liaison for support.