All Eyes on Accreditation
In July 2008, Congress passed the Medicare Improvements for Patients and Providers Act (MIPPA), which, among other provisions, mandated that all outpatient providers of advanced diagnostic imaging services be accredited by a CMS-designated body by January 1, 2012, in order to receive Medicare reimbursement for the technical component of an exam. Advanced diagnostic imaging services are defined as MRI, CT, nuclear medicine, and PET; CMS will select its accrediting organization or organizations by January 1, 2010. With the deadline looming, all eyes are on two of the more obvious choices for accrediting bodies: the ACR® and the Joint Commission (formerly known as JCAHO). In an October presentation to attendees at the fall meeting of the RBMA in Phoenix, Arizona, Leonard Lucey, JD, legal counsel for the ACR, noted that both the ACR and the Joint Commission are mentioned specifically in MIPPA as potential accrediting organizations, and both have applied for the designation.
Michael Kulczycki
Michael Kulczycki, executive director for the Joint Commission’s Ambulatory Accreditation Program, says, “We met with CMS representatives earlier this year about our interest in being designated. They were very supportive of it and are familiar with our process, which focuses not only on patient, but also staff, safety.” Whatever happens on January 1, providers will need to prepare themselves to become accredited by the selected body or bodies, if they are not already. There are advantages to accreditation even without the reimbursement incentive. “For referral sources, it’s evidence of quality, showing that an imaging center can be relied on,” Kulczycki says. Evidence of Quality Shared Imaging LLC, Streamwood, Illinois, is a mobile provider of CT, MRI, and PET/CT imaging services that was motivated to seek Joint Commission accreditation for that very reason, according to Dave Neally, COO. “Some of our competition has been accredited for a while, and we’ve been getting more and more requests as to what our accreditation status is from potential customers,” he says. “Internally, we were pushing back from it because of the time and attention it takes, but after we got started, we found it actually helped our operations in some areas that were deficient in the past.” Kulczycki notes that accreditation is also a sign of quality to an increasingly well-informed patient population, and can even be useful in driving additional reimbursement. “Accreditation is a sign to the patient that the imaging center has taken that extra step and allowed an outsider to evaluate the operation,” he says. “In Florida, in the MRI environment, accreditation can actually lead to more reimbursement under worker’s compensation. We’ve also seen and heard that accreditation status helps customers recruit and retain qualified staff.” The Joint Commission’s imaging segment currently accredits around 75 organizations representing over 700 sites of care, ranging from fixed diagnostic imaging centers to mobile providers and from single-site to multisite groups. “That gold seal of approval, the official designation of our accreditation, is widely recognized in the payor community and among the public,” Kulczycki says. Tamara Boriss, PET/CT manager and compliance administrator at Shared Imaging, says, “It really shows that we’re committed to providing quality care.” Safety in the Spotlight With safety issues increasingly preoccupying both imaging providers and CMS, Kulczycki emphasizes the Joint Commission’s focus on both patient and staff safety. “For any provider, accreditation is a way to help manage the risks inherent in providing care,” he says. “Our standards help imaging centers become familiar with and assess the risk for community-acquired infections so that they can take preventative steps as necessary and be proactive.” Examples offered by Kulczycki include both obvious concerns for imaging centers, such as safe injection practices for contrast media, and emerging issues, such as the prevalence of infection in MRI patient mats. “We use evidence-based literature and best practices to identify recurring problems and what organizations can do to prevent them,” he says. “We have an expectation of accredited customers that they monitor and respond to these Sentinel Event Alerts.” Boriss notes that for Shared Imaging, accreditation helped standardize processes on all of the company’s mobile units, which has made it easier for both operational and field staff to do their jobs. “We learned more about infection control and quality assurance, and our field-staff members like the fact that they can go out on any unit and everything is exactly the same,” she says. “It’s a comfort to them, as well as an educational tool.” Neally adds, “As we grow, we can take that standardization and put it into each new state where we start business.” What to Expect Accreditation is a top-down appraisal of the systems and processes an imaging center has in place; the Joint Commission’s standards are shaped by evidence-based guidelines, consensus from outside experts, and a Professional Technical and Advisory Committee, which currently has representation from both RSNA and the Association for Medical Imaging Management. Kulczycki notes that the Joint Commission’s surveyors each see between 50 and 125 organizations a year, “so they bring to the organization they are evaluating experience related to compliance with our standards, as well as other leading practices from an ambulatory environment. We hear from customers that this is important to them.” Surveyors issue a preliminary report to organizations immediately, giving them the opportunity to address any issues that could prevent them from achieving their accreditation. “Customers have a lot of resources to turn to from us when they have questions,” Kulczycki says. “We have two groups of staff here to address issues with our standards, and account executives that serve only ambulatory customers.” Neally says, “The pre-survey feedback really helped us be prepared for what they were looking for; we didn’t get too many recommendations back because we were meeting most of their guidelines already.” To be considered for CMS designation as an accrediting body, the Joint Commission proposed six new elements to add to its standards, including more specific qualifications for a site’s medical director. Should the Joint Commission be selected by CMS, those currently accredited by the organization will be grandfathered in, as long as they maintain their accreditation after 2012. “On their next accreditation survey, we would look at the additional elements of performance we’ve added,” Kulczycki says. “I’m confident that the application we put in with CMS will be received favorably,” he continues. “We fully recognize and encourage that organizations have choices when it comes to accreditation, and we certainly don’t anticipate being the major provider in this area, but we wanted to be a choice for imaging. I’m comfortable in our ability to be named as an accreditor.” Cat Vasko is editor of and associate editor of Radiology Business Journal.