By Ernesto A. Cerdena, PHDc, RT, CRA, FAHRA
In April 2013, the Medical Imaging & Technology Alliance (MITA) released a new set of standards for CT imaging (XR-29). These standards are related to radiation dose optimization and management. MITA has established four components, namely 1) DICOM dose structured reporting, 2) dose check, 3) Automatic Exposure Controls (AEC), and 4) pediatric and adult protocols. While the proposed standards appear to be patient safety focused, MITA failed to consider how to operationalize these standards and the capital cost it will require in order for hospitals to be in compliance.
The AHRA Regulatory Affairs Committee, led by Sheila Sferrella, dove deeper and conducted a survey of our more than 5,000 AHRA members at 1,800 facilities in August of this year. With a 29% response rate, the results came from 491 member organizations. 56% of respondents stated they had CT scanners that were compliant, and 36% indicated they did not expect to be compliant with XR-29 by the January 1, 2016 deadline. AHRA, in collaboration with the RBMA, ACR, and HFMA sent a letter to CMS requesting a delay of the implementation. However, this past weekend, the Department of Health and Human Services (DHHS) made its final rule and passed the NEMA Standard XR-29-2013:
“Section 218(a) of the PAMA added a new section 1834(p) of the Act. Section 1834(p) of the Act requires for certain computed tomography (CT) services reductions in payment for the technical component (TC) (and the TC of the global fee) of the PFS service and in the hospital OPPS payment (5 percent in 2016, and 15 percent in 2017 and subsequent years).”
The DHHS also added that “to implement this provision, in the CY 2016 PFS proposed rule (80 FR 41716), we proposed to establish a new modifier to be used on claims that describes CT services furnished using equipment that does not meet each of the attributes of the NEMA Standard XR-29-2013.We proposed that, beginning January 1, 2016, hospitals and suppliers would be required to use this modifier on claims for CT scans described by any of the CPT codes identified in this section (and any successor codes) that are furnished on non-NEMA Standard XR-29-2013-compliant CT scans.”
AHRA, its Board of Directors, and the Regulatory Affairs Committee share the sentiment of disappointment that CMS did not delay the implementation and failed to understand the operational challenges of meeting the XR-29 standards by January 1, 2016. To assist our members with the implementation, AHRA will develop educational support through webinars, articles, and discussion forums relevant to XR-29. These resources will be offered free to members.
On a positive note, AHRA’s first virtual Fall Conference concluded last week. Over 330 registrants enjoyed high quality and a highly convenient conference without incurring the travel cost, and with plenty of continuing education credits. The virtual conference was comprised of top ranking, nationally renowned speakers who addressed the most relevant issues in the medical imaging industry today, led by our keynote speaker Dr. Richard Duszak, Vice Chair for Health Policy and Practice, Department of Radiology and Imaging Sciences, Emory University School of Medicine. While the live events may be over, the presentations and CE credits will continue to be available until the end of this month – so it’s not too late to sign up!
And an early Happy National Radiologic Technology Week! We hope that you enjoy the free buttons and posters to celebrate the occasion and to honor our dedicated technologists and radiology staff. Please share photos of your celebrations!
Enjoy the rest of the fall season and see you all at RSNA!
Sferrella S. Preparing for the costs of XR-29. HFM (Healthcare Financial Management) [serial online]. October 2015;69(10):38-41. Available from: Business Source Complete, Ipswich, MA. Accessed November 2, 2015.
Ernesto A. Cerdena, PHDc, RT, CRA, FAHRA is the president of the 2015-2016 AHRA Board of Directors. He is the director of diagnostic imaging/radiology services at Waterbury Hospital in Waterbury, CT. He can be reached at firstname.lastname@example.org.