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CHAMP legislation targets radiology reimbursement and accreditation

Radiology Administrator's Compliance and Reimbursement Insider, October 1, 2007

If passed, the Children’s Health and Medicare Protection Act of 2007 (CHAMP) could mandate imaging center accreditation standards and nonphysician certification requirements for radiology professionals. The House approved the legislation in August. It will soon hit the Senate floor as part of the Congressional effort to reauthorize the State Children’s Health Insurance Programs (SCHIP). Although many radiology officials support federally mandated quality measures for imaging services, there’s plenty of financial and compliance details in the proposal to cause concern.

Proposal details

The House proposal would, among other items, condition Medicare Part B payment for diagnostic imaging services on accreditation and impose personnel credentialing requirements. CHAMP calls for annual surveys and personnel certification for a large number of diagnostic imaging modalities.

The proposal would require those working with diagnostic imaging to obtain certification from a professional organization, licensure, or by another method. Although many states have begun to implement minimum requirements for radiology technologists and other nonphysician imaging practitioners, no standard, nationwide credentialing requirement exists. Further, CMS currently only requires nonphysician personnel to meet any credentialing standards if the imaging center is enrolled as an IDTF.

Industry reaction

Despite general support for the legislation, some industry associations hope to convince Congress to change certain parts of the proposal.

CHAMP’s current provisions act merely as an equipment certification requirement, says Orrin Marcella, assistant director of congressional affairs for the American College of Radiology (ACR).

“[Although] the framework of a good accreditation policy is there, [the proposal] is not [a true] accreditation, because language added in the final markup removes the physician component of facility accreditation,” Marcella explains.

He believes the current language neglects to indicate whether technologist certification for accreditation applies. The ACR says it will advocate for full certification requirements for all providers of advanced modalities as the bill moves forward in the legislative process, says Marcella.

The American Society of Radiologic Technologists (ASRT) says CHAMP should incorporate the educational and certification standards set forth in another bill—Consistency, Accuracy, Responsibility, and Excellence in Medical Imaging and Radiation Therapy (CARE).

The CARE bill sets out stronger educational and certification standards than CHAMP, according to ASRT. In an August 2 press release, the society also criticizes CHAMP for failing to set standards for “all individuals performing medical imaging and radiation therapy in all healthcare settings instead of only setting standards for diagnostic imaging examinations and leaving out interventional and therapeutic procedures.”

The CHAMP and CARE bills differ in their definitions of radiation imaging, according to Christine Lung, director of government relations for ASRT. The CARE bill definition is more expansive than that in the CHAMP legislation. It applies to anyone who performs radiation imaging and therapy. CHAMP’s definition excludes radiation therapy and interventional radiology.

Reimbursement changes

CHAMP also proposes the following reimbursement changes that might adversely affect radiology:

Pay cuts. Although the bill would end global billing—a move the ACR supports—it also increases the discount from 25% to 50% for the technical component of multiple procedures performed in a single imaging session involving consecutive body parts.

Although the bill focuses on Medicare Part B payments and nonhospital services, the 50% reduction for contiguous body parts will certainly affect hospital-based imaging, says Lung.

Meanwhile, CMS has suggested sweeping imaging changes in proposed rules for the Medicare physician fee schedule (MPFS), outpatient prospective payment system, and inpatient prospective payment system, adds Pam Kassing, MS, senior director of economics and health policy for the ACR. “The provisions in the proposed legislation would be additive to whatever Medicare has proposed for these payment systems and the Deficit Reduction Act of 2005,” she says.

Separate conversion factors. The CHAMP legislation could also affect future reimbursement for radiologists because it divides physician services into six categories with different conversion factors, according to the ACR.

“A separate service category with its own reimbursement calculation for imaging services is troubling for radiologists,” says Marcella.

One of Congress’s reasons for creating the six categories is to hold physicians accountable for growth in their specific service area. “[Because] imaging is a fast-growing Part B service, the likelihood is that it will be subject to large reimbursement reductions year after year under this policy,” says Marcella. However, this strategy doesn’t work for radiologists, who are consulting physicians dependent on referrals from others, explains Marcella. “ACR believes all physicians who order imaging services over the course of treatment for their patients should be responsible for the growth in volume of imaging.”

Challenges to the bill

The final SCHIP reconciliation product may be quite different than the current CHAMP version. Congress might also put the matter aside until later in the legislative session. This would give the radiology industry more time to influence the final product. Regardless, Marcella expects Congress to continue its focus on accreditation and credentialing for radiology.

That’s because private payers have already adopted facility accreditation standards, says Lung. The CHAMP bill confirms that Congress is paying attention to industry trends.

More and more insurers are requiring facilities to be accredited to perform MRI, CT, PET, and nuclear medicine studies. This means the equipment, technologists, and physicians must meet certain standards in order to receive payment, Marcella adds. So far, this is a quality measurement mechanism that imaging organizations support.

The most important concerns are education and credentialing standards, not only for patient safety, but also to ensure the proper performance of the imaging exam, says Lung. Administrators and practice managers should educate physicians about the potential impact of the CHAMP provisions, says Marcella. Facilities should either pursue facility accreditation now or build the costs for future accreditation requirements into upcoming budgets, says Lung. Also examine staff members’ credentials to ensure they have the appropriate experience and qualifications to perform their current duties, she says. Make sure staff members have completed appropriate continuing education and competency requirements for the accreditation programs.

Insider sources

Pam Kassing, MS, senior director of economics and health policy, American College of Radiology, 1891 Preston White Drive, Reston, VA 20191, 703/648-8936; www.acr.org.

Christine Lung, director of government relations, American Society for Radiologic Technologists, 15000 Central Avenue SE, Albuquerque, NM 87123, 800/444-2778, Ext. 1308; cjlung@asrt.org; www.asrt.org.

Orrin Marcella, assistant director of congressional affairs, American College of Radiology, 1891 Preston White Drive, Reston, VA 20191, 703/648-8936; www.acr.org.

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