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MIPPA mandates imaging accreditation for all providers

Radiology Administrator's Compliance and Reimbursement Insider, October 1, 2008

Facilities have two years to earn ACR or IAC approval

Are you ready for accreditation? The Medicare Improvements for Patients and Providers Act of 2008 (MIPPA), which was passed in July, calls for providers of advanced diagnostic imaging services (e.g., MR, CT, PET, and nuclear medicine) to be accredited in order to receive payment for the technical component of those services by January 2012.

“This is a very positive development for the imaging industry and provides a focus on quality. It could not have come at a better time,” says Sandra Katanick, CAE, CEO of the Intersocietal Accreditation Commission (IAC) in Columbia, MD.

This is a step forward for the industry, says Krista Bush, director of diagnostic modality accreditation at the American College of Radiology (ACR) in Reston, VA.

“The accreditation process will be good for radiologists and their practices,” says Thomas W. Greeson, Esq., healthcare attorney at Reed Smith, LLP, in Falls Church, VA. Accreditation will help improve or eliminate imaging facilities that are not up to standard and, thus, will benefit those who are already accredited or who can meet high standards, he explains.

The bill requires providers of advanced diagnostic imaging services, inclusive of nuclear medicine, MR, CT, and PET, obtain accreditation as a condition for Medicare reimbursement by 2012, Bush says.

In addition, Katanick says, it establishes a two-year voluntary program to collect data regarding physician compliance with criteria to determine the appropriateness of advanced diagnostic imaging services furnished to Medicare beneficiaries. Most importantly, the legislation and accreditation will result in improved patient care, Katanick and Bush say. Katanick says the portion of the legislation requiring accreditation states:

• Accreditation programs must ensure physicians and staff maintain the proper level of training and education
• Facilities use imaging equipment that adheres to strict standards of performance and operates under proper safety guidelines
• All imaging providers establish and maintain a quality assurance program, thereby upholding the standards of quality care for patients, particularly senior citizens

ACR and IAC likely accreditors

CMS has not yet chosen the accrediting bodies but will do so by 2010. Although not set in stone, CMS will likely choose the ACR and the IAC since both organizations have extensive experience accrediting imaging entities under current requirements by private insurers and some states, Bush says. In the case of the ACR, the mammography accreditation program is a federally recognized program under the Mammography Quality Standards Act and administered by the FDA. Both are national nonprofit organizations that provide a peer review process of accreditation designed to evaluate and accredit diagnostic imaging facilities.

Note: RACRI subscribers can access a special report with questions and answers from the ACR and the IAC at www.hcpro.com/content/71716.pdf; scroll to p. 9.

During the past several years, various health insurers and medical specialty societies have set accreditation requirements. (See “Current accreditation program man- dates” on p. 7 for a list of some of the requirements.)

For example, UnitedHealthcare requires freestand-ing outpatient facilities and physician offices that perform diagnostic imaging services to meet accreditation standards developed by the ACR and the IAC, or forego reimbursement.

The IAC currently maintains five accrediting divisions providing accreditation for facilities performing noninvasive vascular testing, echocardiography, nuclear cardiology, general nuclear medicine, and/or PET imaging, MRI, and CT scanning.

For the ACR, a committee of ACR members, each an expert in a specific imaging modality, develops and supervises accreditation for that division. Each module evaluates clinical and phantom images based on set criteria.

The ACR’s peer review accreditation program in- cludes mammography, breast ultrasound, stereotactic breast biopsy, ultrasound, radiation oncology, CT, MRI, nuclear medicine, and PET.

Reasons to comply

In addition to accreditation now being mandated before CMS will pay for certain procedures, accreditation also offers the following benefits for your practice:

Improved patient care and image accuracy. This is the foremost benefit, Bush and Katanick say.

Opportunities for educational and organizational growth. The assessment of your practice should be a positive exercise. “It’s not a punitive process,” says Katanick.

An impetus for change. A qualified voice can prompt your practice to improve and draw attention to weaknesses, such as aging equipment that administrators previously might have been reluctant to replace, Bush says.

Improved patient and payer confidence. Approval from qualified peers demonstrates the organization takes industry standards and government requirements seriously. It shows dedication to image quality and the quality of care provided to patients.

Resolution of additional mandates. Your practice may use the review to meet additional state, federal, or third-party payer reimbursement criteria.

Three tips to prepare for accreditation

The accreditation process takes approximately four to six months, Bush says. The ACR and the IAC accredit for a three-year period. Bush and Katanick offer the following tips to prepare for accreditation:

Obtain relevant reference materials. Visit www.acr.org and www.intersocietal.org to view the specific accreditation guidelines and standards. Pay attention to the systematic instructions offered in the online applications, Katanick says, adding that both sites provide a wealth of information.

Get organized. Gather information regarding all imaging modalities your facility offers from the ACR and the IAC Web sites. Collect other information such as:

• ACR or IAC accreditation identification numbers
• Contact information for supervising physicians and technologists
• Basic technical and modality-specific information for each unit

Ask for help. The ACR has technical experts available at 800/770-0145, or you can reach IAC technologists at 800/838-2110.

Insider sources

Krista Bush, director, diagnostic modality accreditation, American College of Radiology, 1891 Preston White Drive, Reston, VA 20191, 703/648-8900; kbush@acr.org.

Thomas W. Greeson, Esq., Reed Smith, LLP, 3110 Fairview Park Drive, Suite 1400, Falls Church, VA 22042-4503, 703/641-4200; tgreeson@reedsmith.com.

Sandra Katanick, CAE, CEO, Intersocietal Accreditation Commission, 8830 Stanford Boulevard, Suite 306, Columbia, MD 21045, 800/838-2110; skantanick@intersocietal.org, www.intersocietal.org.

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