AHRA Regulatory Milestone

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37.5_reg affairs_headshotMelody MulaikBy Sheila M. Sferrella, CRA, FAHRA and Melody W. Mulaik, MSHS, CRA, FAHRA, RCC, CPC, CPC-H 

AHRA is continuing its focus on participating in and shaping the healthcare industry in regulatory issues that impact our members. Every year, CMS issues Proposed Rules for all types of services (hospital outpatient, physician, inpatient, etc) with proposed regulatory changes for the coming year. The industry is allowed to submit comments on these changes to help guide implementation.

This year, the AHRA Regulatory Affairs Committee selected two key issues from the Hospital Outpatient Prospective Payment System (HOPPS) Proposed Rule to comment on to guide CMS’s understanding and perspective. On August 31, AHRA submitted our letter to CMS to address the NEMA Standard XR-29 and Low-Dose CT Lung Screening billing requirements.

In the past, AHRA has followed some of our colleague associations in their response letters. With the addition of Capitol Associates to our regulatory affairs team in July, we proactively engaged with several organizations (ACR, HFMA, and RBMA) to lead the request for a one year delay in the enforcement of XR-29. The Regulatory Affairs Committee felt that a one year delay is necessary to adequately address all of the operational issues in ensuring accurate reporting of a new modifier to identify exams performed on non-compliant XR-29 CT scanners. As part of this initiative, AHRA worked collaboratively with key industry partners to communicate and coordinate this response.

For Low-Dose CT Lung Cancer Screening, AHRA asked CMS for clarification on the requirement of the assessment by the ordering physician and payment to the imaging provider. We will also be submitting comments on the Medicare Physician Fee Schedule (MPFS) Proposed Rule in regards to Clinical Decision Support (CDS), and we will share that information with you, as well.

At this point, we wait for CMS’s response in the Final Rule due to be published around November 1, 2015.

The Regulatory Affairs Committee members are:

Chair: Sheila Sferrella, CRA, FAHRA
Luann Culbreth, CRA, FAHRA
Jim Miller, CRA
Melody Mulaik, CRA, FAHRA
Penny Olivi, CRA, FAHRA
Jacqui Rose, CRA, FAHRA
Carlos Vasquez, CRA, FAHRA

Read a copy of both the AHRA comment letter to CMS and the CT Compliance Survey that many of you completed.

If you have any questions, please email or call. Thanks. Take care.

  • Sheila and Melody

Sheila M. Sferrella, CRA, FAHRA is senior vice president, Regents Health Resources, Franklin, TN. She can be contacted at ssferrella@regentshealth.com.

Melody W. Mulaik is president and co-founder of Coding Strategies, Inc. She may be contacted at melody.mulaik@codingstrategies.com.


  1. Sheila and Melody:

    Excellent article on the AHRA Regulatory Milestone. You both hit the three most important elements- XR-29, CT Lung CA Screening, and CDS that are impacting the imaging operations across the country. Our hospital for one is unable to meet the XR-29 compliance due to the cost of upgrades for the 3 scanners. We are only able to replace a single slice unit (The Smithsonian wanted to buy it). Kidding aside, we are absolving the cost of 5% reduction in reimbursement during the first year. Hopefully, the collaborations with the AHRA/RBMA/ACR/HFMA and other alliances will influence the policymakers and approve the moratorium for one year. Many thanks for all your hard work (including the entire committee) on this. Great work!


  2. Sheila and Melody

    Following up on Ernie’s comments my feeling is that you have very succinctly captured the salient points of these initiatives. Staging and implementation phaising is critical to an organizations transition. Only with feedback from members and a collaborative approach with other organizations can regulators know how to make these changes in a way that will be both highly effective and cost sensitive.

    Well done.


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