The American College of Radiology (ACR) and the Medical Imaging & Technology Alliance (MITA) both issued statements underlining their support for clinical decision support (CDS) in advanced imaging following a op-ed by American Enterprise Institute fellow Scott Gottleib, MD.
Dr. Gottleib wrote in both the Wall Street Journal and in Forbes magazine that while the idea behind CDS is good, the current legislative language implementing CDS for Medicare physicians is not. His beef? The language is not specific enough to ensure the Centers for Medicare and Medicaid Services (CMS) and the secretary for Health and Human Services (HHS) cannot use this provision to dictate to doctors how they should practice medicine.
According to Dr. Gottleib, the legislation as currently written requires Medicare ordering physicians to consult a website with imaging appropriateness guidelines and then submit the guideline to CMS when they order the imaging procedure. “Outlier” ordering physicians who contradict the guidelines more often than their peers will then have to submit their orders for prior authorization starting in 2020.
However, the legislation does not spell out exactly who will be involved in creating the appropriateness guidelines or put strict limits on what tests and procedures this system can be applied to, and that is a big problem, according to Dr. Gottleib.
“Federal agencies take vast discretion to interpret and reinterpret the rules,” he warned in Forbes magazine. “Unless they are tightly bound by legislative text, don’t expect them to follow the spirit of the law, or the best of intentions. Agencies march to their own agendas.”
But MITA’s Executive Director, Gail Rodriguez, noted in a statement that Dr. Gottleib’s article was inaccurate and that changing physician ordering patterns through CDS is a much better alternative than the arbitrary across-the-board cuts and reimbursement restrictions that have been used in the past to attempt to lower what Medicare spends on advanced medical imaging.
“Over the years, Congress and Medicare administrators have tried to enact harmful policies – indiscriminately cutting payments, blocking coverage of new technologies, and erecting bureaucratic barriers to patient care. A thoughtful, evidence-based appropriate use criteria policy is a much better approach to guiding medical imaging utilization,” she noted on MITA’s website. “Appropriate use criteria empower physiciansby providing them with the latest information to help inform the discussion with their patients on what care is best.”
The ACR for its part did not directly reference Dr. Gottleib’s articles, but did issue a strong affirmation of its support for CDS following the articles' publication.
“The ACR strongly supports the imaging provisions in [the SGR Repeal and Medicare Beneficiary Access Act of 2013]. This approach will help medicine transition from volume-based to quality-based care without affecting access or interfering in the doctor-patient relationship. The legislation represents a landmark step by Congress and a validation of a cornerstone of the College’s Imaging 3.0 initiative that increases quality of care and preserves health care resources,” stated Paul Ellenbogen, MD, FACR, chair of the American College of Radiology Board of Chancellors in a message emailed to the media.