ASE Joins Letter Responding to Appropriate Use Criteria Provisions in the MACRA Modernization Proposal

On May 8, ASE joined cardiovascular societies in sending a letter to Representatives John Joyce, Greg Murphy, and Kim Schrier offering feedback on the draft MACRA modernization proposal. The societies focused their comments on Section 205, which would modify the Appropriate Use Criteria (AUC) data collection requirement for applicable imaging services. While the cardiovascular community broadly supports AUC as a tool for promoting evidence-based, patient-centered care, the societies raised significant concerns about establishing a stand-alone AUC consultation mandate. They noted that the prior AUC program under PAMA revealed major operational and policy shortcomings, including clinicians’ inability to access their own societies’ AUC due to limitations of CMS-qualified clinical decision support mechanisms (CDSMs), and that CMS itself moved away from a separate mandate in favor of more integrated approaches. The letter requested that Section 205 be removed from the draft and instead urged lawmakers to leverage AUC within a restructured MIPS framework to more broadly promote high-value care across services, not just imaging.

ASE’s participation in this letter reflects the direct stakes echocardiography practices have in how AUC requirements are designed and implemented. During the voluntary testing phase of the PAMA AUC mandate, cardiologists found they could not always consult their own societies’ AUC, because hospitals were limited to whatever AUC were available in their contracted CDSMs. This is a problem for echo specifically, since AUC vary considerably across organizations in how clinical scenarios are structured and how appropriateness is rated. A stand-alone compliance framework could push clinicians toward AUC that do not reflect the best or most current evidence for cardiac imaging. ASE continues to advocate for policies that give clinicians flexibility, support sound imaging decisions, and ensure that quality programs reflect how echocardiography is actually practiced.