State Model


STATE MEDICARE RADIOLOGY ADVISORY COMMITTEE

I. Rationale

Resolution 42, passed at the 1999 ACR Council Meeting, commissions the ACR to develop a model for state chapters to coordinate input from the various sub-specialties of radiology and the RBMA into local Medicare policy and specifically into the Carrier Advisory Committee process. This model emphasizes the ACR’s commitment to actively advise and support radiologists’ interactions with Medicare at the local level.

Radiology subspecialty societies’ (SCVIR and ASNR) and the Radiology Business Managers Association’s (RBMA) interest in local Medicare policy and the Carrier Advisory Committee process has led to the development (or plans for the development) of national subspecialty networks for each of these groups. Interaction between the ACR’s Network of Carrier Advisory Committee representatives and the subspecialty and RBMA networks has been informal but generally highly productive. However, without a coordinated mechanism for interaction between the networks, there is potential for successes to be only hit or miss and also potential for Medicare Carrier Medical Directors to get conflicting information from their radiology advisors. Formalization of the relationship between the subspecialty networks and the ACR CAC network will minimize these risks. The best chance for success with local Medicare policy issues occurs when radiology speaks with a unified voice.

Additionally, the development of a local committee will expose additional radiologists to the CAC process and allow several radiologists an opportunity to develop good working relationships with the CMD. This mechanism will provide a smooth transition when there is attrition of the radiology CAC representative.

The goals of establishing a formal Medicare Radiology Advisory Committee within the ACR state chapters are as follows:

  1. Inform the state chapters and the ACR CAC Network representative that individuals with specific subspecialty knowledge or billing and coding information are available and interested in assisting with local Medicare policy and the CAC process.
  2. Provide a specific mechanism for the participation of individuals representing the interests of subspecialty societies in the local CAC process.
  3. Provide a mechanism for the timely dissemination of local Medicare policies to subspecialty representatives so that they can in turn receive timely comment from expert panels or economics councils of their subspecialty society.
  4. Maintain the ACR as the central repository of all information related to local Medicare policies including LMRPs, CPT/ICD databases and white papers regarding future local policy issues. The ACR will ask subspecialty societies to seek comment from the ACR prior to direct communications with HCFA – either nationally or locally through the CMDs. The local radiology CAC representative should be aware of all communications to his or her CMD regarding radiology issues, and for most issues, the CAC should be the source of the information to the CMD. In turn, the ACR will seek opinion and comment from subspecialty societies prior to direct communication with HCFA regarding Medicare issues in their subspecialty.

II. Participants

Radiology Representative to the Carrier Advisory Committee
The Radiology CAC representative should serve as chair of the State Medicare Radiology Advisory Committee. This individual is elected or appointed by the state chapter and must be an ACR member. He will become a de facto member of the ACR Network of radiology CAC representatives. This individual may also be a subspecialty society member as well. If the CAC representative is also a subspecialty society member whose society has a local Medicare network in place, he should be the representative to the subspecialty society network as well. Since the Radiology CAC representative is responsible for all local Medicare issues related to radiology, Radiology CAC representatives whose practices do not include general radiology should seek input from general diagnostic radiologists.

The Alternate Radiology Representative to the Carrier Advisory Committee
The Alternate Radiology CAC representative is also elected or appointed by the state chapter, and therefore must be an ACR member. If the radiology CAC representative is a general radiologist, the alternate may be selected from the subspecialty society representatives. However, if the radiology CAC representative is a subspecialty network member then it is advisable for the chapter to select a general radiologist to perform the role of alternate radiology CAC representative. The alternate CAC representative should attend as many CAC meetings as possible in order to develop a personal relationship with the Carrier Medical Director and the other members of the Carrier Advisory Committee.

Subspecialty Society Participants
Both the SCVIR and the ASNR are in the process of recruiting state representatives to serve as local Medicare advisors. Economics sections of other radiology subspecialty societies may follow similar paths in the future. The participants in the subspecialty networks may be appointed nationally or state chapters may recruit individuals who would like to serve in this capacity. Their names could then be submitted to the sponsoring society for consideration.

This section will outline general guidelines for the participation of representatives of subspecialty societies in the local CAC process. How these individuals report to and interact with their sponsoring societies will be variable and depend on the needs and desires of the subspecialty society.

ACR membership is desirable but not required of the subspecialty representative; however, ACR membership is required for election or appointment as the alternate CAC representative by the state chapter.

The radiology CAC representative will keep the subspecialty representatives apprised of all Medicare issues affecting radiology in the state. The subspecialty representatives will be expected to carefully review local policies related to their subspecialty area. Appropriate comment and consultation should be supplied to the radiology CAC representative. Consultation with the expert panels and economics councils of their sponsoring organizations is expected. Comments obtained from subspecialty expert panels or economics councils should be made available to the radiology CAC representative and forwarded to the ACR when appropriate.

It is expected that there will be instances where the subspecialty representative will be asked to take the lead role in presenting comment on local policies to the CMD. This process will be different from state to state. Some states have very strict policies regarding participation in CAC meetings by non-members. Other states have very open policies and substitution by the subspecialty representative for the radiology CAC or joint presentations are possible. The subspecialty representatives should attend as many CAC meetings as possible in order to establish personal contact with the CMD and other non-radiology members of the Carrier Advisory Committee.

Subspecialty representatives are encouraged to seek an actual seat for their subspecialty on the CAC for their state. This is important in states where the Carrier Advisory Committee actually votes on adoption of specific policies and the language therein. Obtaining a separate CAC seat for their subspecialty should not lessen or change the participation of the subspecialty representative in the State Medicare Advisory Committee.

Radiology Business Managers Association Members
The RBMA has a fully functioning national network devoted to local Medicare policy in place now. They have assigned an RBMA member in each state to assist the Radiology CAC representative in the review of local policies and to provide input about billing and coding issues. The RBMA representative will also be a member of the State Medicare Radiology Advisory Committee. However, this individual cannot serve as the official alternate radiology CAC representative. The RBMA should be welcomed into the CAC process. Their input is invaluable at both the sate and national levels. RBMA can seek seats on the Carrier Advisory Committee by obtaining the Medical Business Managers position available on some CACs. This has been a way for some RBMA members to obtain CAC seats. Again, this is most important in states where the CAC vote is used to determine local policy.

III. Composition and Operation of the State Medicare Radiology Advisory Committee
 
Guidelines for Composition of the Committee

  • Radiology CAC representative, Chair
  • Subspecialty society representatives (alternate radiology CAC representative)
  • General radiologist (if radiology CAC representative represents a subspecialty society)
  • RBMA member

Guidelines for Operation of the Committee

The committee should develop a mechanism for rapidly disseminating Local Medical Review Policies to the committee members, the ACR and the subspecialty organizations represented on the committee. The radiology CAC representative should distribute this material to the committee members and the ACR in a timely manner. The subspecialty representatives are responsible for distributing the policies to their respective organizations.

Electronic dissemination of the material is favored whenever possible. However, fax and standard mail can also be used effectively. The latter methods reduce the amount of time available for comment. If presented in electronic format to the ACR, ACR staff can redirect policies for comment to the appropriate individuals including the state’s subspecialty and RBMA representatives. If some Carriers remain disinclined to provide proposed local policies in digital format, through scanners and OCR software, it may be possible for the ACR to convert paper documents into digital documents which can then may sent by e-mail to the designated individuals. Each committee must decide which is the favored method of communication for their situation. The ACR will provide whatever support is possible to aid information dissemination.

Carrier Advisory Committee representatives are encouraged to send the final LMRPs to the ACR. These serve as the principal data source for helping states where there is no existing policy. Policies particularly favorable to radiology will be deemed “Model Policies.” These can be sent out on short notice to help states comment on similar LMRPs.

All committee members should participate in review of model policies and attend as many CAC meetings as possible. The latter activity facilitates the establishment of a personal relationship with the CMD and other non-radiology committee members. These relationships are extremely valuable when a committee member presents comment on an LMRP or succeeds the radiology CAC representative.

Meetings between the State Medicare Radiology Advisory Committee and the CMD outside of the official CAC meeting are typically possible and are strongly encouraged. Some states have a scheduled quarterly meeting with the CMD. Others merely set up meetings as problems arise. The frequency is left to the discretion of the Committee.

IV. Conclusion

This model is a proposal from the ACR to assist local radiologists’ with local Medicare issues. The ACR believes that coordination of subspecialty and RBMA input has specific advantages, particularly in states where radiology CPT codes have been the target of local Medicare policies. However, there is no mandate placed on the state chapters. Each state chapter and CAC representative retains the freedom to pursue a course they believe is in the best interest their state’s radiologists. The ACR is committed to providing as much assistance as possible to each CAC representative. The ACR believes adoption of this model by the state chapters, the subspecialty societies and the RBMA will create an organized and potentially more effective mechanism for dealing with local Medicare issues.