PAMA Imaging

Advanced imaging orders (i.e. MRI, CT, PET) placed by providers in outpatient and emergency departments settings for Medicare fee-for-service patients must be evaluated by a clinical decision support (CDS) tool starting in January 2020.

This mandate is part of the Protecting Access to Medicare Act of 2014 (PAMA) enacted by the Centers for Medicare and Medicaid Services (CMS). Although many details have yet to be defined by CMS, this mandate will have wide-ranging effect on ordering providers, radiologists and facilities.

Preparations and education will be completed throughout 2020, and starting January 1, 2021, CMS will begin withholding payment from radiologists and other providers and facilities that read studies without proof of consultation. Outlier ordering providers may also be required to obtain official prior-authorization before ordering these advanced imaging studies.

CMS Medicare Guidelines for Advanced Imaging


Providers using HHC Epic:

  • Starting August 15, 2020, a clinical decision tool that has been integrated with HHC Epic orders will automatically generate recommendations that pop-up whenever providers sign advanced imaging orders for qualifying conditions and patients.  The tool is designed to work in the background, utilizing data already documented in patient charts.
  • Providers will be able to either accept the offered recommendation that appears in the pop-up or ignore it.  The tool will automatically generate and attach a CMS mandated code evidencing the use of the clinical decision tool during the placement of the qualifying orders.  The mandated code will be passed through to CMS claims for bill payment.  
  • Non-compliance will have financial consequences for the ordering provider, radiologist, and facilities that read the studies, effective January 1, 2021.

Providers who do not use Epic:

  • Please check with your electronic health record vendor for an appropriate solution.
  • Non-Epic providers may also utilize a clinical decision tool provided by Stanson-Premier for Hartford HealthCare.


Clinical decision tool for non-Epic users

Registration for first-time users
Clinical decision tool portal

Questions about the Stanson-Premier clinical decision tool? Contact Mike_Grove@premierinc.com

Frequently Asked Questions

What is happening?

A new CMS mandate requires that certain advanced imaging orders be evaluated by an approved clinical decision support (CDS) tool.

Why is this happening?

This rule is part of the Centers for Medicare and Medicaid Services (CMS) Protecting Access to Medicare Act (PAMA) of 2014, which is goes into effect Jan. 1, 2020, with financial consequences for non-compliance effective Jan. 1, 2021.

What services are affected by this regulatory mandate?

Advanced imaging orders (ex. MRI, CT, PET) placed in the outpatient setting or emergency department.

Does this apply to all patients?

The mandate applies to Medicare fee-for-service patients.

When does this become effective?

The mandate became effective on January 1, 2020, but 2020 is considered a preparatory and educational year.

If the rule is not followed after January 1, 2021, CMS will begin withholding payment from providers, radiologists and facilities that read these studies if proof of consultation is not provided. This may also result in delayed patient care and poor patient experience.

What do I need to do now?

  • Providers to begin utilizing approved technology that includes evidence-based best practice guidelines when ordering advanced diagnostic imaging services for Medicare fee-for-service patients with certain (suspected) conditions.
  • Outlier ordering providers may be required to obtain an official prior-authorization before ordering these advanced imaging studies. 

What should HHC Epic users do to comply with this mandate?

  • HHC in partnership with Premier-Stanson Health has integrated Stanson’s clinical decision support tool (CDS) with HHC Epic orders.  This tool is designed to work in the background, utilizing data already documented in patient’s chart. 
  • As of January 1, 2020, this tool began running in silent mode, which means no pop-ups are visible to providers during qualifying conditions and patients. The silent mode allows necessary testing to ensure proper functioning.
  • Starting August 15, 2020, this tool will be switched on more visibly to providers:
    • Automatic recommendations will pop up when providers sign advanced imaging orders for qualifying conditions and patients in compliance with the CMS regulatory mandate.
    • Providers will be able to accept the offered recommendation that appears in the pop up, provide more information, or ignore it.  The tool automatically attaches a CMS mandated code to the advanced imaging order that will get passed through to CMS claims for bill payment.

What happens for providers who do not use Epic in their offices?

For providers who do not use Epic in their offices, we urge that you check with your EHR vendor for an appropriate solution.  Stanson-Premier is providing the CMS compliant tool for Hartford Healthcare and offers free web-portal access for non-Epic providers that do not have a tool in their EHR. Contact Mike_Grove@premierinc.com for more information.

For more information