In 2008, when Congress passed the Medicare Improvements for Patients and Providers Act (MIPPA), the January 2012 accreditation deadline for providers of advanced imaging seemed distant, but it’s near enough to call for action now. For those advanced diagnostic imaging services (ADIS) providers still unaccredited, the choices available in accrediting bodies have also become clear since the law passed: The ACR®, the Intersocietal Accreditation Commission (IAC), and the Joint Commission are the only accrediting organizations approved by CMS to handle MIPPA accreditations.
Under MIPPA, only IDTFs and physician suppliers billing for the technical component of MRI, CT, PET, or nuclear-medicine exams under the Medicare Physician Fee Schedule (MPFS) need to be accredited. Hospitals that bill CMS for advanced imaging are not involved in MIPPA-mandated accreditation, since they are accredited in other ways.
The MIPPA accreditation requirements had long been sought by the ACR. Pamela Wilcox, RN, MBA, assistant executive director for quality and safety for the ACR, says, “The ACR was heavily involved in getting the accreditation language into MIPPA. Getting it passed in 2008 took two years. We’d been talking to Congress much longer, but this initiative was a two-year effort.”
One goal of ACR lobbying was to impose uniform quality standards on nonradiologist imaging providers, such as cardiologists and orthopedists. “We believe if Medicare is paying for ADIS, then it ought to be getting high-quality images,” Wilcox says.
Mandatory accreditation by January 1, 2012, is the heart and soul of the MIPPA provision on imaging standards—section 135(a)—regarding outpatient providers. After that date, unaccredited ADIS providers billing Medicare for the technical component of the designated procedures won’t be paid.
The law also lays out what all the accrediting bodies agree are basic compliance standards:
- the qualifications of nonphysician personnel must be specified and met;
- the qualifications and responsibilities of medical directors and supervising physicians must be spelled out and documented;
- procedures to ensure the safety of staff and patients must be in place;
- procedures to ensure the reliability, clarity, and technical quality of diagnostic images must be in place and must be verified;
- there must be methods in place to assist patients in obtaining imaging records; and
- imaging centers must have a way to notify (and must notify) CMS of any change in imaging modalities that takes place after accreditation.
These are the six standards that accrediting bodies must establish as having been met by applicants. For the ACR, the key provision has to do with reliability, clarity, and technical quality of images. The IAC also stresses this requirement, but it relies more heavily on a review of physician-by-physician radiology reports and complex procedural protocols to make sure that standards are met.
The Joint Commission takes what it calls a more holistic approach, focusing on facilities’ systemic characteristics and quality-control programs. It lets applicants determine their own methods of achieving image quality, although it does validate them.
There are major differences among the three accrediting bodies. Potential applicants should understand these differences in order to select the most suitable path to accreditation.
ACR accreditation might be considered the gold standard by many in the industry because of its rigor in assessing image quality. While the IAC and the Joint Commission might dispute that characterization, it does focus on what the ACR plays as its trump card: the quality of the images required to achieve accreditation. The ACR’s accreditation proceeds scanner by scanner, with each machine required to produce high-quality scans of actual patients, in addition to undergoing performance analysis using third-party phantoms to test each machine.
“The ACR’s program evaluates actual clinical images from actual patients. The IAC does that too,” Wilcox says, “but the IAC does not use phantoms. We think phantoms are critical. You can’t see if the equipment is operating optimally from patient films.”
That’s because patients vary physically, and radiologists can’t always see machine discrepancies on clinical images. With phantoms, where the objects being scanned are the same, machine discrepancies do show up, Wilcox says. Settings that might lead to overexposure, for instance, would