OP-15 for imaging effectiveness in atraumatic headache is coming, vigorously opposed by many. To date, most of the opposition has been in principle, or with specific clinical concerns.
This is a different approach to the problem - looking at whether the patients that CMS identified as "inappropriate" were actually appropriate exceptions. This was a retrospective chart review of 748 charts that were referred back to 21 hospitals as "inappropriate" following a "dry run" of OP-15. Based on individual chart review, the authors found documentation of one of the exclusion criteria in 489 of them - 479 based on the clinical criteria, and 35 based on administrative criteria (some met both). They then look at those 259 patients for whom there is no CMS exception for their CT, and they claim that 136 of those were clinically warranted. They therefore conclude that only 125 of the original 748 were accurately identified by this quality measure as inappropriate use of CT in atraumatic headache, and that this measure is garbage.
And, a quick Google News search finds an extensive parade of indignant headlines pulled from ACEP's press release, condemning the measure.
But, this study misses the point. It's not CMS' responsibility to comb through individual charts to find these exclusion criteria. The onus is on clinicians and hospitals to ensure their documentation clearly expresses the indications for CT in those cases that meet the exclusion criteria, and the purpose of this dry run is to help hospitals identify where the information they are supplying to CMS is deficient.
Then, I expect CMS to take a low opinion of the additional patients in whom these authors felt the imaging was clinically warranted. Of the 78 patients for whom the authors felt ACEP guidelines for imaging were met, 73 of them met only the Level C recommendation: >50 years of age with a new type of headache and a normal neurologic examination. Then, there is another set of patients with headaches on warfarin, who had recent neurosurgery, or had known hydrocephalus that they claim are misclassified by CMS - but I can't see how the misclassification isn't on the documentation end, as headaches in all those patients should meet ICD-9 339.44 "Other complicated headache syndrome," which is an exclusion to the rule as well.
So, even just on first pass, I'm not sure this is an effective tool with which to influence revision of OP-15. I expect this measure to go into effect as planned - and it will be up to us to document appropriately and thoroughly, and then to monitor and demonstrate that compliance results in measurable patient harms.
"Assessment of Medicare’s Imaging Efficiency Measure for Emergency Department Patients With Atraumatic Headache"