ACR Statement on GAO Report Regarding the Effect of the Deficit Reduction ACT of 2005 on Medical Imaging Utilization and Cost

The September 2008 GAO report on the effects of the Deficit Reduction Act of 2005 (DRA) on medical imaging reimbursement revealed that the DRA cuts were far deeper than the Congressional Budget Office (CBO) initially stated. This GAO report confirms 2005 ACR statements that the cuts are approximately three times that of the initial Congressional Budget Office (CBO) estimates.

While the DRA lowered Medicare imaging costs by decreasing per unit reimbursement for examinations, these cuts disproportionately impact radiologists. Radiologists do not typically order advanced imaging examinations because patients are referred to them by other providers for the purpose of receiving scans.

Moreover, the DRA may actually increase inappropriate utilization because physicians who own imaging equipment and refer their patients to those scanners; a process known as self-referral, are able to simply increase the number of tests that they order to make up for cuts to reimbursement for each individual scan.

In fact, the June 2008 Government Accountability Office (GAO) report regarding growth in medical imaging services identified self-referral as a significant driver of increased imaging utilization and associated cost to the Medicare system.

The ACR supports recent legislative initiatives to curtail inappropriate utilization of imaging studies by implementing mandatory accreditation of imaging providers and the development of pilot projects to reduce inappropriate utilization by peer to peer interactions using appropriateness criteria which can provide guidance as to which scans; if any, are most appropriate for a given indication at the time of order entry.

The ACR also supports the initiative  of the Center for Medicare and Medicaid Services (CMS) that require all physician offices providing advanced imaging studies to register as independent diagnostic testing facilities (IDTFs) in order to improve transparency and allow appropriate regulation as currently exists for IDTFs.

These quality based initiatives reflect a targeted and sustainable approach to be built upon if Congress and CMS are moving forward with addressing unnecessary imaging utilization.