The Medical Imaging and Technology Alliance (MITA) has submitted a comment letter to the ranking members of the House Ways and Means Committee and the Senate Committee on Finance supporting the emphasis the committees placed on appropriate utilization criteria (AUC) in developing its sustainable growth rate reform framework discussion draft.
Late last month, the two committees released a draft version of a policy to replace the SGR formula that includes language requiring that ordering physicians consult appropriateness criteria for advanced imaging services for Medicare patients.
"A thoughtful, evidence-based appropriateness guidelines policy is a much better approach for addressing any inappropriate use than proposals that would enact across-the-board reimbursement cuts, block coverage for scientifically-proven technologies, or erect indiscriminate, bureaucratic barriers to appropriate care," MITA Executive Director Gail Rodriguez wrote.
Rodriguez added that the "fine details" of an AUC policy will determine its eventual success, but that a poorly designed policy "could also inadvertently limit appropriate use and negatively impact patient care and outcomes."
Such a policy should contain key components, she wrote. For example, it should include a process for updating the criteria and accounting for the development of new technologies, as well as the method through which clinicians access that criteria, and the costs of that access.
Also, she said, it should take into account the process of benchmarking "AUC compliance vs. AUC consultation without promoting 'cookie cutter medicine' that does not allow for physician and patient decisions that deviate from clinical guidelines," and provide and facilitate the gathering of accurate and actionable feedback from clinicians to compare their behavior with their peers in order to encourage practice improvements.
MITA also suggested that in order to "maximize" the reach of its final AUC policy, Congress should direct the Centers for Medicare & Medicaid Services to hold stakeholder discussions on how the policy fits in with other parts of the SGR reform draft proposal.
For example, the draft proposal also contains language that would create a small prior authorization program for clinicians whose ordering of advanced imaging exams for Medicare beneficiaries is inconsistent with the ordering patterns of their peers. In the past MITA has opposed the introduction of large-scale pre-authorization Medicare requirements.
"Given that the discussion draft takes a more targeted approach, MITA looks forward to learning more details regarding this provision and how it would work with the AUC provision above to address concerns regarding inappropriate utilization," Rodriguez said.
To learn more:
- read the letter from MITA (.pdf)