The following statement was released today by Douglas B. Fridsma, MD, PhD, FACP, FACMI, President and CEO, American Medical Informatics Association (AMIA) regarding the Medicare Appropriate Use Criteria Program described in the 2017 Physician Fee Schedule Final Rule.
AMIA supports CMS’ efforts to leverage clinical decision support (CDS) to support evidence-based medicine. We see the Medicare Appropriate Use Criteria (AUC) Program as a potential model for informatics-informed approaches to improve health outcomes and lower costs, and we support many of the provisions as finalized by this rule. However, the implementation deadline of January 2018 leaves little room for error.
By CMS’s own admission, “The number of clinicians impacted by the scope of this program is massive as it will apply to every physician or other practitioner who orders or furnishes applicable imaging services. This crosses almost every medical specialty and could have a particular impact on primary care physicians since their scope of practice can be quite broad.”
Given this scope, thoughtful and thorough execution will be needed to make sure ordering professionals, furnishing professionals, CDS Mechanism developers, and EHR vendors are ready for a January 2018 deadline. Should the market struggle over the next six months to deliver CDS Mechanisms that are efficiently integrated with workflows and reasonably address ordering professionals’ clinical scenarios, we strongly advice CMS to reconsider its start date.
AMIA stands ready to leverage its long-standing expertise in CDS and clinical informatics to assist CMS as it endeavors to implement this ambitious and important program.