September 6, 2016
Mr. Andy Slavitt
Centers for Medicare & Medicaid Services
Department of Health and Human Services
7500 Security Boulevard
Baltimore, MD 21244-1850
Re: CMS-1654-P: Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2017
Comments submitted via www.regulations.gov
The Society of Cardiovascular Computed Tomography (SCCT) appreciates the opportunity to comment on CMS-1654-P: Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2017. SCCT is the international professional society representing physicians, scientists, technologists and nurses advocating for research, education and clinical excellence in the use of cardiovascular computed tomography.
SCCT reviewed with interest the proposed implementation provisions of the appropriate use criteria statute that requires ordering professionals to consult with appropriate use criteria prior to ordering advanced diagnostic imaging services. Based on the provisions outlined in the proposed rule, SCCT does not believe it is reasonable or feasible to expect ordering professionals to consult AUC by January 1, 2018. Rather, we support the stance of the American Medical Association (AMA) and ask CMS to consider a delay and require full implementation of this mandate by January 1, 2019.
We are also concerned that CMS appears only to consider volume and cost of services to Medicare beneficiaries as the criteria for determining the priority clinical areas where the AUC will first be implemented. We believe these factors should not be the sole determinant of a priority clinical area. We encourage CMS to review the targeted priority clinical areas outlined under the ABIM Foundation’s Choosing Wisely initiative. This initiative is the result of significant collaboration with medical professional societies and offers a venue where medical specialties provide input on specialty specific imaging modalities and inappropriate use of diagnostic imaging services.
We also ask that CMS provide more focus on the free clinical decision support tool that must be made available to ordering professionals. This is a significant component of the AUC program that may ease the burden of participation for many providers.
Thank you for your consideration of these views. If you require additional information please contact Ahmad Slim, MD, SCCT Chair of Government Relations and Advocacy, at firstname.lastname@example.org.
Leslee J. Shaw, PhD