Health Affairs August 31, 2023
On July 13, 2023, the Centers for Medicare & Medicaid Services (CMS) proposed to pause the implementation of the statutorily mandated Medicare imaging Appropriate Use Criteria (AUC) program and to rescind extensive regulations that the agency had promulgated for that program. Conceived as an alternative to prior authorization for high-cost imaging for Medicare beneficiaries, the AUC program includes statutorily mandated clinical decision support for imaging orders delivering clinical content developed by CMS-approved entities. Due to the statutory mandate, CMS’ regulatory options are limited; it has concluded that it has the authority to pause the program and rescind its own regulations, but CMS remains obligated under the governing statute to develop a workable AUC program. While acknowledging this requirement, CMS explicitly...
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