The American College of Radiology backs the ROOT Act, which would resume the Appropriate Use Criteria program for advanced diagnostic imaging, aiming to reduce unnecessary radiation exposure and lower Medicare costs.

The American College of Radiology (ACR) is urging Congress to pass the Radiology Outpatient Ordering Transmission (ROOT) Act (S.1692) to promote value-based care, help Americans avoid unwarranted imaging and radiation exposure, and reduce Medicare spending on low-value imaging.

Introduced in the United States Senate by Sen Marsha Blackburn (R-TN) and Sen Catherine Cortez Masto (D-NV), the bipartisan ROOT Act would amend the Protecting Access to Medicare Act (PAMA) of 2014, to ease and allow implementation of PAMA requirements that providers consult physician-developed appropriate use criteria (AUC) prior to ordering advanced diagnostic imaging for Medicare beneficiaries. The bill reflects input from multiple medical societies and stakeholders.

Congress mandated that the PAMA Imaging AUC program be implemented in 2017, but regulatory interpretation of the statute has caused delays. The Centers for Medicare and Medicaid Services (CMS) declared an “indefinite pause” to the AUC program in the 2023 Medicare Physician Fee Schedule Final Rule despite the agency’s acknowledgement of the program’s potential benefits—including more than $700 million in annual Medicare savings.

ROOT Act technical changes to PAMA aim to ensure that CMS implements the AUC program without delay and in a manner that is least burdensome to providers and patients. Such changes include:

  • Replacing a “real time” claims processing requirement with a provider attestation that they consulted a qualified AUC program prior to ordering an advanced imaging study.
    • Compliance data would be collected (subject to CMS review/audit) – and reviewed by hospitals/health systems to educate providers and help manage utilization.
  • Providing additional provider exclusions within the existing PAMA statute – including:
    • Ordering providers who participate in clinical trials.
    • Small and rural practices (as defined by CMS).
  • Ensuring appropriate oversight and compliance mechanisms by adding a review study (based on several years of collected data) to help Congress and the Administration at such time to determine any needed measures to improve the program.

According to the ARC, AUC-based clinical decision support systems enable providers to access AUC and order exams in real time (at the point of care) and do not delay care nor interfere in doctor-patient decision-making. Providers are not required to order a specific exam recommended by AUC but to show that they consulted AUC prior to ordering.

“If the ROOT Act is not passed, AUC program benefits, including reduced unwarranted imaging, increased patient safety, more patient-focused care, and significant savings to Medicare beneficiaries and the Medicare system will remain unrealized,” reads a release from ARC.

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