MIPPA Accreditation: 20 Months to Go
As the deadline inches closer, radiology providers around the country are scrambling to meet new CMS accreditation requirements for MRI, CT, and nuclear medicine. By mandate of the Medicare Improvements for Patients and Providers Act (MIPPA), in order to receive Medicare reimbursement for these modalities, imaging centers must be accredited by the Joint Commission, the ACR®, or the Intersocietal Accreditation Commission (IAC) on January 1, 2012.
Tammie Sloper, director of marketing for the IAC, says, “We are recommending that they get started right away. One of our greatest concerns with MIPPA is that the law stipulates that they are actually accredited on January 1; some of the facilities are more familiar with private-payor policies, which are based on submission, rather than accreditation.”
All three accrediting bodies stress the importance of commencing the application process as soon as possible; multiple rounds of feedback and submission may be required, which can take months. The ACR recommends that facilities apply by July 1, 2011. “Although we’ve streamlined our processes, a limiting factor is that practices have to find the appropriate clinical images, and that can take a while,” Pam Wilcox, RN, MBA, ACR assistant executive director for quality and safety, notes. “If they wait until after July 2011, the chances of meeting the deadline will get slimmer every day.”
Likewise, Sloper recommends that facilities seeking IAC accreditation submit their applications by summer 2011, as does Michael Kulczycki, executive director for the Joint Commission’s Ambulatory Accreditation Program. “We encourage people to get started now,” he says, “and to apply no later than June 2011 to have the process completed by December 31 of that year.” Typically, Kulczycki says, organizations will apply within four to six months of when they hope to be accredited, but he adds that after the Joint Commission does its on-site survey, “We leave the leadership a report, and they have about two months to respond to the findings; then, there’s a period where we review and assess that, so after the survey date, it can take anywhere up to 2.5 months for organizations to get their final decisions.”
Each of the CMS-appointed accrediting bodies takes a slightly different approach to the process. “Our accreditation programs are focused specifically on imaging,” Wilcox says. “We have requirements for the physicians, medical physicists, and technologists, and for clinical image quality, quality-control procedures, and quality-assurance activities. We also have an assessment of phantoms and radiation dose in CT as part of the evaluation, which allows you to assess the technical capability of the equipment and whether it is optimized.”
ACR accreditation applications may be submitted online, although related images must be submitted via CD. “Even if the imaging center gets accredited, there may be comments appended to the final report about what it can do better,” Wilcox adds. “Our focus is on making this an educational process.”
At the IAC, Sloper says, “The philosophy is that (as the word intersocietal would denote) we are taking all the specialties involved in a given type of imaging and bringing them together to write standards for quality.” The board of directors includes radiologists, orthopedic surgeons, physicists, neurologists, cardiologists, and others. “Those individuals are instrumental in writing the standards, which are the fundamental component of each of our accreditation programs, ranging across every aspect: operational and administrative functioning of the laboratories, background and training of the staff, the physical facility, exam interpretation, reports, records, safety, and patient confidentiality,” Sloper says.
Aside from the requisite images that must be submitted on film or CD, the IAC’s accreditation program is virtually paperless. Sloper says that laboratories can access the application from any computer. Each application requires the submission of both normal and abnormal cases, along with the corresponding final reports. “That is a distinguishing point,” Sloper notes. “Our applications require some kind of pathology, and that final interpretation is examined.”
Kulczycki emphases the Joint Commission’s holistic view. “The other two groups accredit by modality, while we accredit for the organization,” he says. “It’s a much broader view of what’s important for quality, as well as patient and staff safety.” MIPPA also mandates that all accrediting bodies conduct unannounced on-site evaluations of applicant facilities, a required component of Joint Commission accreditation since 2006. “We’ve had experience conducting those and working with our customers so that they understand what’s required for the unannounced-survey process,” Kulczycki says.
All three accrediting bodies stress that they are there to help facilities through the process, and all three have resources for those currently undergoing, or getting ready to commence, the application process. “There’s no disadvantage to getting to work on it now and submitting as soon as you’re ready,” Sloper advises. Though the MIPPA requirements only apply to freestanding imaging centers at present, Wilcox warns hospital-affiliated radiology groups to be on the lookout. “In the future, Congress will be looking at extending accreditation requirements to hospital-based practices as well,” she says.
Cat Vasko is editor of Medical Imaging Review.