CMS has postponed the deadline for clinical decision support. But change is coming, and radiologists will be at the forefront.
We've heard the rallying cry so many times now that it almost feels cliché. We need to stop rewarding volume and start prioritizing value in health care. Last spring, Sylvia Burwell, secretary of Health and Human Services, announced an ambitious target — 90 percent of Medicare payments will be tied to value by 2018.
Shortly thereafter, the Medicare Access and CHIP Reauthorization Act (MACRA) did away with the flawed SGR payment update formula for Medicare, setting us all on the road to value-based payments and putting 9 percent of our fee-for-service revenue at risk (either for an increase or decrease) by 2022.
With such accelerated transition goals in place, it was truly unfortunate that CMS admitted in the Final Rule for 2016 it would not meet the legislated kick-off date of January 2017 for the implementation of clinical decision support (CDS) for advanced imaging in the Medicare program. CMS may have been responding to pressure from other physician specialty societies, several of which made the case for a delay despite recognizing the benefits of the initiative. This is clearly a new paradigm for the agency, but CDS is a value-based win-win. If it’s too hard to implement a program based on well-established guidelines already in use in many large health systems, it’s hard to see CMS achieving its broader goals.
But as I read the rule language and felt understandably frustrated, I remembered the goal that we set in the ACR Strategic Plan:
This is a perfect opportunity for us to act as leaders. Bringing along all the stakeholders — even those who find change hard — is the mark of an effective leader. I’m choosing to take CMS’ procrastination as a call to action and I hope you will join us in this.
Our senior citizens covered by Medicare deserve to benefit from a tool that ensures they receive the most appropriate and highest-valued imaging. Our federally funded health system should not be allowed to continue to grow unchecked if we have a proven way to spend our money more wisely.
The untiring work of your ACR Economics and Informatics Commissions helping CMS understand the CDS process has not gone to waste. We will continue to engage often and collaboratively with CMS to ensure that the year delay we believe to be outlined in the rule does not drag out any longer.
Many of you have written to me to ask how you can get your physician colleagues and health systems engaged around CDS. ICD-10 consumed a lot of organizational bandwidth for many, and January 2017 felt too far off. So what now? The good news for many of you is that your health system may already have committed to CDS. For those of you who still have to beat the drum, my advice is to use all the tools we have available to help your colleagues and your leadership understand what you can offer in terms of higher value care.
A great way to start is to sign up for the Radiology Support, Communication, and Alignment Network (R-SCAN). This is another win-win. You earn your American Board of Radiology Maintenance of Certification Part 4 credit and, at the same time, you teach your colleagues about how CDS can help them in their practice.
The program was recently awarded a $3 million Transforming Clinical Practice Initiative grant by CMS,so it’s clear that even if CMS wasn’t able to meet the January 2017 implementation deadline, it recognizes the potential of this tool to improve care and lower costs. The topics are from the Choosing Wisely initiative (read more at choosingwisely.org), which has good recognition among our referring physician colleagues. It’s not punitive or patronizing toward our partner physicians, but R-SCAN provides just the platform you need to get the word out about how effective CDS is and, even more importantly, the role radiologists play in its optimal implementation.
The ACR’s CDS resource page has a wealth of materials that you can repurpose to educate your health system leadership. For those of you in accountable care organizations or other risk-sharing models, never miss an opportunity to talk about the contribution that appropriate imaging can make to improving quality and reducing costs.
As we think about the various new payment models generated by the MACRA legislation, CDS will be at the foundation of several of the programs we will propose to CMS. For example, we’ll develop clinical practice improvement metrics that recognize the role radiologists play in amplifying the impact of CDS. We’ll think about how effective imaging utilization drives better use of resources and again propose that radiology’s role be recognized. We’ll be engaging with those of you already using CDS to understand how best to craft these recommendations.
From the Chair of the Commission on Economics
By Geraldine B. McGinty, MD, MBA, FACR, Chair