Posted by By Nathan Baugh and Jay Mazurowski
CMS announced on Friday that they were creating a new modifier, QQ, for voluntary Appropriate Use Criteria (AUC) reporting. The modifier may be used on claims with dates of service on or after July 1, 2018. We should emphasize that this QQ modifier is an entirely optional modifier that can be used when the ordering professional consults with a Clinical Decision Support Mechanism (CDSM). You can read the full CMS announcement here: https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM10481.pdf.
Background
The Protecting Access to Medicare Act (PAMA) of 2014 established the Appropriate Use Criteria program with the goal of increasing the rate of appropriate advanced diagnostic imaging services provided to Medicare beneficiaries. Under this program, at the time a practitioner orders an advanced imaging service for a Medicare beneficiary, he/she will be required to consult a qualified CDSM.
Effective July 2018, the voluntary participation period for this program will begin. During this period, ordering professionals may choose to consult qualified CDSM when ordering advanced imaging services; and furnishing professionals (Radiology) may “choose” to report limited consultation information on their Medicare claims with a modifier. Medicare Administrative Contractors (MACs) will accept this new “QQ” modifier on the same claim line as advanced imaging CPT codes on both the technical and professional claim.
When this program is more fully implemented (expected January 1, 2020), consultation with a qualified CDSM will be required and certain AUC data elements regarding the ordering professional’s consultation must be added to the furnishing professional’s claim. These data elements include:
- Tthe ordering practitioner’s National Provider Identifier (NPI);
- The CDSM used (there are multiple qualified CDSMs available); and
- Whether the order adheres, does not adhere, or is not applicable to the AUC.
CMS does not have guidance at this time regarding these requirements. The AHRA Regulatory Affairs Committee is working with CMS and others in the imaging community to figure out how to report these AUC data elements in the least burdensome way possible.
Nathan Baugh is an associate at Capitol Associates, a government relations/consulting firm based in Washington, DC, who has partnered with AHRA on their regulatory affairs issues. He can be reached at baughn@capitolassociates.com. Jay Mazurowski is the deputy executive director at AHRA. He can be reached at jmazurowski@ahra.org.
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