HomeTown Health received clarification from CMS today related to CAHs and AUC imaging reporting. Here is their response on this subject.
The AUC criteria is applied based on the location where the exam is performed, not by anything else. So when it is performed in a CAH the criteria does not apply.
“If the provider ordering imaging is on a Critical Access Hospital, the imaging occurs in the critical access hospital, but the person reading the image is located offsite, does that require an AUC?”
It does not. And the reason is because of the setting where the imaging is furnished. Since the imaging service was furnished in a Critical Access Hospital, then that is all that needs to occur. In situations where the radiologist for example will submit a separate claim for the professional component of that service, the place of service that they put on their claim is the place of the patient at the time that they were furnished the imaging service. So it’s not based on the location of the radiologist that is reading the claim.”
They have also said the following:
“So if a practitioner that is located within a Critical Access Hospital orders imaging for a patient, that patient goes to an imaging center somewhere else that is considered an outpatient hospital or an ASC, then we would expect that claim for the imaging services to contain appropriate use criteria consultation information and it is again on that ordering practitioner to do the AUC consultation.”
This means your physicians that order outside of a CAH will need to comply with the AUC guidelines.