Last week, it was announced that the National Decision Support Company, or NDSC (http://nationaldecisionsupport.com/), is being acquired by Change Healthcare (https://www.changehealthcare.com/). As you probably already know, NDSC was selected to provide electronic access to the the American College of Radiology’s AUC’s (https://www.acr.org/Clinical-Resources/Clinical-Decision-Support) with their tool ACR Select™ which is can provide ACR’s national standards based, clinical decision support database comprising over 3,000 clinical scenarios and 15,000 criteria to a CPOE system (Computerized Physician Order Entry).
While perhaps not a direct factor in the acquisition, last year’s decision pushed back twice the imaging decision-support provisions of the Protecting Access to Medicare Act (PAMA) of 2014, with mandated compliance now set to begin on January 1, 2020. The upside of the delay provides an opportunity for more organizations to adopt and implement clinical decision support (CDS) capabilities ahead of the compliance date. Physicians who order advanced diagnostic imaging exams such as CT, MRI, PET, nuclear medicine will need to consult government-approved, evidence-based appropriate use criteria (AUC), through a clinical decision support (CDS) application. NDSC’s CareSelect™ is just such a solution.
Probably more of an impact is the trend toward the relationship between clinical decision support and payor applications such as Change Healthcare’s InterQual AutoReview™. These relationships are aimed at “streamlining the utilization management and authorization processes, which today are labor intensive, redundant, and expensive,” as the NDSC-Change Healthcare announcement states (http://nationaldecisionsupport.com/change-healthcare-announces-acquisition-national-decision-support-company/).
Tying clinical decision support to the payor side is what others are doing as well. Take for example, eviCore (https://www.evicore.com/solution/pages/provider.aspx). eviCore CDS (formerly HealthFortis CDS) is CMS-certified to meet the 2020 mandate for CDS for outpatient imaging, featuring Appropriate Use Criteria (AUC) available through Provider Led Entity (PLE) and eviCore partner Medical Guidelines Institute. This is another example of CDS on the payor side.
Providing clinical decision support AUCs requires qualification by CMS (Centers for Medicare and Medicaid Services) as a Provider Led Entity (PLE) - https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Appropriate-Use-Criteria-Program/PLE.html. The site lists PLE’s that have been qualified for providing Appropriate Use Criteria (ACU). Given the growing number of AUC criteria, clinical decision support applications are under pressure to support multiple AUC as defined by PLE’s. For example, Medicalis, a unit of Siemens Healthineers (https://www.medicalis.com/), has designed its application to support multiple PLE AUCs, providing added flexibility to organizations looking to implement CDS in a minimally invasive way to enable a local standard of care.
The distinction between payor and provider may be significant in terms of the implementation of CDS. There potentially are differences of opinion in terms of payor versus provider driven CDS, as physicians may be apprehensive about having payors determine the validity of exams ordered. Change Healthcare, in effect, has their bases covered with the acquisition of NDSC.
Implementing CDS will further require greater cooperation between providers and payors, as well as greater interoperability between systems. With or without PAMA, it is clear that CDS is here to stay as a tool to improve quality while reducing costs, and it will play a greater role in the delivery of healthcare services. To use the famous lyrics of Bob Dylan’s song, “the times they are a changin,” and thus it is with healthcare and clinical decision support.
