Well, the sun is setting on Phoenix and I'm checking in from the Sky Harbor airport just a few minutes before my flight back to LA. But never fear! Thanks to the miracle of mobile broadband, I can bring you one last update from the show. And it's a doozy: Leonard Lucey, JD, legal counsel for the ACR, on the new accreditation requirements created by MIPPA.
First, a lesson in recent history. MIPPA was passed by the House of Representatives in July 2008, after a presidential veto; the legislation was primarily created to extend expiring Medicare provisions. But, as Lucey points out, the bill also includes the words "for other purposes," and it turns out one of those other purposes is imaging accreditation. Though the imaging provisions of the bill total only 40 pages out of a whopping 1100, they still pack a considerable punch.
Here's what you probably already know. Beginning January 1, 2012, all outpatient providers of "advanced diagnostic imaging services" will need accreditation by a CMS-approved body in order to receive Medicare reimbursement. Advanced diagnostic imaging services (henceforth referred to as ADIS) include:
* Nuclear medicine
"Why were these four modalities chosen?" asked Lucey. The answer is simple and predictable: they're advanced, changing technologies, and they have the largest growth in terms of both number of exams performed and in terms of cost.
CMS must designate its accrediting bodies by January 1, 2010. The ACR looks like a shoo-in. Another organization mentioned in MIPPA is the Joint Commission, a less obvious choice for very obvious reasons: "I did a presentation with the Joint Commission about three years ago where we talked about how our programs were complementary," Lucey noted. "It'll be interesting to see what happens if the Joint Commission is selected."
So what do you need to do to get up to speed? Well, if you're already accredited by the body CMS designates, nothing for a year. If not, it's time to get crackin'. For now, CMS says that you will not be reimbursed for any procedures performed until you are accredited, although the ACR is lobbying for a grace period while the accreditation process is underway. Still, Lucey advises:
* Get accredited as soon as you can. Follow all the steps very carefully, and call the accrediting body with any questions.
* Put someone in charge of organizing the accreditation material.
* Make sure the clinical images you send are the best you have and that they've been reviewed by a clinician.
* If you get a deficiency, find out what your options are for addressing it.
* Stay current with the accreditation requirements.
* Reapply for accreditation in a timely fashion.
To get in touch with the ACR's accreditation team, use the contact information below:
Theresa Branham, CT/MR: firstname.lastname@example.org
Carolyn MacFarlane, NM/PET: email@example.com
Krista Bush: firstname.lastname@example.org
Leonard Lucey: email@example.com
And that, ladies and gentleman, concludes our statread coverage of this year's RBMA fall educational conference. However, we'll be including much of what we learned at the show in upcoming issues of ImagingBiz.com, so if you're not already a subscriber, sign up here and stay on top of all the action!