CMS Delayed the CDS Mandate for Advanced Imaging—Will Providers Take Advantage?

CMS released its 2018 Medicare Physician Fee Schedule (MPFS) proposed rule on July 13, and it included two pieces of good news for imaging facilities across the United States.

First, the rumored 50-percent payment reduction to the technical component of mammography services—a cut many within the industry strongly opposed—was not proposed. And second, CMS proposed delaying the start date of its clinical decision support (CDS) mandate for advanced imaging services from Jan. 1, 2018, to Jan. 1, 2019, with 2019 being treated as an “educational and operations testing year.” This extends the deadline for referring providers to begin consulting CDS when placing advanced outpatient imaging orders, and for furnishing providers to submit documentation of CDS use on Medicare claims for reimbursement.

That strange noise you hear? It’s the sound of referring physicians, radiology administrators, radiologists and health IT managers letting out big sighs of relief. I’ve spoken to numerous thought leaders from various segments of the healthcare industry over the last several months who were worried about CDS implementation. It was coming too soon, they said. Nobody will be ready in time.

In fact, just last month at AHRA 2017 in Anaheim, Calif., I overheard a group of attendees complaining about what a pain in the neck CDS implementation was going to be for them. Judging by their tone and the four-letter words they dropped during their discussion, I can only assume they weren’t prepared to begin on time.

While the delay is terrific news for leaders who had fallen behind, I hope everyone sees this as an opportunity. It is a second chance to catch up, have some long-needed conversations with the rest of your team and push ahead. For guidance, turn to sources such as the American College of Radiology, the Advisory Board and, yes, past issues of Radiology Business Journal. Ask a lot of questions. Think outside the box. Do whatever it takes to be ready for CDS implementation by 2019, even if it does end up being a “testing year.”

CMS may not be so forgiving next year. Play with fire any longer and, well, you just may end up getting burned.

Thanks for reading,

Michael Walter, Editor