By Jacqui F. Rose, CRA, FAHRA
On behalf of the AHRA Regulatory Affairs Committee, I would like to thank the members who participated in our CT compliance surveys. This data was included as a key piece of our comments to CMS on XR-29, and it also allows us to better inform the industry of what our members need.
As you know, CT compliance with the XR-29 regulation was mandated by January 1, 2016; otherwise a 5% reduction in Medicare payment for scans performed on non-compliant scanners would be implemented. The first survey we conducted was in the summer of 2015 and the second in the first quarter of 2016. The response rate on the first survey was slightly higher than the second (29% of member facilities versus 24% in 2016); the facility sizes were very similar in each, as well as the total number of CT scanners. Interestingly, there was only a 3% change in compliance from 2015 to 2016 and there will continue to be a significant number of non-compliant scanners in 2017. We also garnered important information regarding how facilities are billing the modifier on non-compliant scans and compliance letter acquisition.
Jacqui F. Rose, CRA, FAHRA is the director of medical imaging and telecommunication services at Premier Health-UVMC in Troy, OH. She is a member of the AHRA Regulatory Affairs Committee, as well as the AHRA Board of Directors. She can be contacted at firstname.lastname@example.org.