Over the past few months we have fielded several calls, emails and inquiries for information related to the Clinical Decision Support (CDS) mandate which was passed into law in 2014 as a part of the Protecting Access to Medicare Act (PAMA).
The law set the deadline for CDS implementation for January 1, 2016. The questions we have received have ranged from, “do you sell CDS?” to “what do I need to do before January?”.
In an attempt to answer these questions and others that you may have, we will begin with a series of informational blog posts to address these questions as well as movements in the rules related to CDS.
Here are the four things you need to know about CDS right now.
What is Clinical Decision Support?
In short, CDS is a two-part solution that allows ordering physicians to consult a database that will help them determine the appropriateness of a given exam.
This was included in PAMA to control the unmanaged growth of imaging.
According to Dr. Sarah Reimer, an expert on CDS, one fourth of all advanced imaging cases are clinically inappropriate. To mitigate this and ensure clinical appropriateness of exams, experts have developed CDS as a system to ensure exams ordered are clinically appropriate.
CDS, as proposed, will be a solution comprised of two components. The first component is the Appropriate Use Criteria (AUC). The AUC are a set of guidelines that have been established by a body of clinical and radiology experts and will be consulted to determine if a requested exam is appropriate considering the patient’s history, symptoms, current condition, etc.
This database will be accessed electronically by a “mechanism.” This mechanism, or software program, will allow doctors and ordering physicians to consult the AUC to determine the appropriateness of the exam that is being ordered.
In a hospital setting, this mechanism will most likely be integrated with the EMR which will provide the CDS with patient data ensuring that the appropriate exam is being ordered.
Once appropriateness is met, the mechanism will generate the correct ICD-10 code as well as a code that will verify to CMS that an AUC has been consulted. In an out-patient setting, it is predicted that radiologists and imaging centers will provide physicians with a web portal in order to consult the AUC.
Dates you need to know
As mentioned above, the original date to have CDS in place was January 1, 2017. However, based on recent rulings from the Centers of Medicare and Medicaid Services (CMS) this deadline has been pushed back indefinitely.
The current dates that will have an impact on the CDS roll out are:
- June 30, 2016: CMS will release their list of approved AUC.
- June 30, 2017: It is anticipated that CMS will release the list of approved mechanisms, at which point healthcare providers can begin the implementation of an approved CDS solution for their facility.
What about reimbursements?
Currently, Medicare and Medicaid reimbursements are not affected due to the postponement of the deadline.
However, CMS has been designed and was implemented as a means of replacing the long standing method of pre-authorizations through insurance companies.
Additionally, when CDS does go into effect it will impact reimbursements on CT, MRI, PET and NM. These exams (and eventually all exams) must be consulted against approved AUC to receive reimbursement.
CDS will also have an impact on Meaningful Use Stage 3 (which is also influx at the moment), but it is too early to make a determination on what this effect will be.
Impact of CDS on referring physicians
While it is still too early to understand the sweeping impact that CDS will have on the healthcare community as a whole, you can draw some conclusions based on several pilot programs conducted across the country.
Initially, there has been some skepticism from radiologists as to whether or not ordering physicians would resistance the implementation of CDS. It will create an additional step in their workflow and add additional time in the case that an exam is not deemed appropriate.
At the ACR Conference, Dr. Daniel Durand noted that physicians are accepting of CDS, as it allows them to move away from the drawn out pre-authorization process, it also improved the relationship between radiologists and doctors citing enhanced collaboration between the two healthcare providers.
During the same conference it was recommended that out-patient radiologists begin evangelizing CDS before its implementation, ensuring that referring physicians are on board and accepting of the solution well before it is implemented.
This, in turn, means that when CDS is installed there will be fewer headaches and frustration from the software which could potentially harm these relationships.
Click here to see the full clinical decision support flow chart and download the pdf.
At Novarad, we are working with experts in this field to ensure we are not only your go-to source for information, but also we are researching and working in order to provide you, our customers, with the best solution for CDS as possible.
As more information is available, we will pass that along to you. Should you have further questions or require more information on CDS please comment on our blog or email firstname.lastname@example.org and we will do our best to bring you up to speed on this complex topic.
Sources: Information has been gathered from lectures given on CDS at the both the RBMA Conference and the ACR Conference.
This post was written by Justin Brooks, a product manager at Novarad.