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Dear Chairman Brady, Chairman Roskam, Ranking Member Neal and Ranking Member Levin:

The undersigned organizations thank you for your commitment to cut red tape in the Medicare program to better serve patients. In this regard, we are united by the position that the Medicare Appropriate Use Criteria (AUC) Program for advanced diagnostic imaging, if allowed to take effect, will become yet another duplicative and burdensome regulation.

The Protecting Access to Medicare Act of 2014 (PAMA) established the AUC reporting program. The number of clinicians affected by the program is vast, crossing almost every medical specialty, including primary care. The Centers for Medicare & Medicaid Services (CMS) describes the program as “massive.” CMS began implementation rulemaking in 2015. Even with the publication of the CY 2019 Medicare Physician Fee Schedule Final Rule later this year, the full compendium of regulations for the program will have yet to be written.

When Congress passed the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 it consolidated the legacy physician quality reporting programs into what is now known as the Quality Payment Program (QPP). AUC consultation is inherent within the QPP’s dual tracks: the Merit-based Incentive Payment System (MIPS) and alternative payment models (APMs), both of which hold clinicians accountable for quality and patient outcomes, as well as for resource use. For instance, there are a number of existing measures for appropriate use of imaging in the Quality category of the QPP. In addition, CMS has added consultation of AUC as an Improvement Activity within MIPS — essentially folding key aspects of this program into MIPS.

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