Providers of a advanced diagnostic imaging services, including
physicians, who bill for the technical component must become
accredited by a designated accreditation organization by Jan. 1,
2012 in order to be reimbursed by Medicare, according to a notice
(http://edocket.access.gpo.gov/2010/pdf/2010-1457.pdf) from CMS published in the Federal Register. The notice
approved three organizations to accredit advanced diagnostic
imaging suppliers: the American College of Radiology, The Joint
Commission, and the Intersocietal Accreditation Commission.
Pursuant to the Medicare Improvements for Patients and Providers
Act of 2008 (MIPPA), the Health and Human Services Secretary is
required to designate accrediting organizations for suppliers
furnishing the technical component of advanced diagnostic imaging
services. Advanced diagnostic imaging services include CT, nuclear
medicine, PET and MRIs. X-rays, ultrasound, fluoroscopy, and
diagnostic and screening mammography are excluded from the
definition of advanced diagnostic imaging services. The
accreditation requirement applies to any supplier of the technical
component of advanced diagnostic imaging services. Supplier is
defined as "a physician or other practitioner, a facility, or
other entity (other than a provider of services) that furnishes
items or services under this title [42 USC 1395]." The notice
does not provide guidance as to which entities, if any, may be
excepted from the accreditation requirements.
While it is unclear what criteria the designated organizations
will use for accrediting advanced diagnostic imaging suppliers,
MIPPA provides that the criteria used by the accreditation
organization shall include:
- Standards for qualifications of non-physician medical personnel who furnish the technical component of the services.
- Qualifications and responsibilities of medical directors and supervising physicians, such as training in advanced diagnostic imaging services in a residency program, expertise obtained through experience or continuing medical education courses.
- Procedures to ensure the safety of persons who furnish the technical component of advanced diagnostic imaging services and individuals to whom such services are furnished.
- Procedures to ensure the reliability, clarity, and accuracy of the technical quality of diagnostic images produced by the supplier.
- Procedures to assist the beneficiary in obtaining the beneficiary's imaging records on request.
- Procedures to notify CMS of any changes to the modalities subsequent to the organization's accreditation decision.
The Joint Commission is expected to continue to use many of the same criteria it currently uses in accrediting diagnostic imaging centers, and will likely publish additional guidance and criteria early this year, according to a representative at The Joint Commission. Information on the Joint Commission's criteria for diagnostic imaging centers is available at this link (http://tinyurl.com/y9c5jf8) . It is unclear whether the American College of Radiology and the Intersocietal Accreditation Commission will publish additional guidance as well.
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