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Coalition Comments on CMS’ Proposed Rule
Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the Physician Fee Schedule,
and Criteria for Physician-Focused Payment Models

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CDS Characteristics

  • Electronic Order +

    • Consistent with and adhering to industry standards of data format to promote consistency, portability and interoperability across different health information technology (HIT) platforms
    • Standardized definition of data elements within the order such that cross-reference tables between ordering provider and rendering provider are minimized or eliminated
    • Contains all information necessary for the rendering provider to submit a complete claim and be eligible for payment processing
  • Qualified Decision Support Mechanism +

    • Electronic and computerized; with telephonic consultation or internet consultation with document-based feedback limited to gap-filling situations
    • Interoperable and reliable across different health information technology (HIT) platforms with respect to:
      • Incorporated seamlessly into the imaging order process of the ordering provider
      • Adherence to appropriate use criteria (AUC) with non-adherence conservatively applied.
      • Transmission of required information to all required entities: (1) QDSM, (2) adherence/non-adherence, and (3) National Provider Identifier (NPI) of ordering provider
  • Appropriate Use Criteria +

    • Developed or endorsed by national professional medical specialty societies or other entities
    • Based on medical evidence
    • Published and available for reference
    • Not based on cost considerations
    • Updated regularly
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