Appropriate Utilization of Imaging Services: A Policy Update
Both lawmakers and federal regulatory agencies are troubled by the increase of diagnostic medical imaging procedures being performed by nonradiologist physicians. The ACR has been told by jurisdictional congressional committees and federal agencies staff that closing the loophole for in-office ancillary services found in the Stark self-referral law is a political and logistical impossibility—implementation and enforcement of such a policy being of particular concern to Congress and the administration.
As an alternative to the Stark approach, the ACR is in the process of developing a policy, which is modeled after selective privileging by private insurance providers, and, if implemented, would achieve the goal of reducing imaging utilization, providing significant savings to the federal government and increasing the quality of patient care. The College has worked closely with the Medicare Payment Advisory Commission (MedPAC) to assist it in establishing a policy focusing on quality of care and patient safety as the means for obtaining cost savings. MedPAC appears to be moving in this direction as shown by its recent draft recommendations presented to the commission on December 10, 2004.
College leadership and staff have also met with jurisdictional congressional committees, the Office of Management and Budget, and private payers to discuss appropriate imaging. The ACR has also met with other medical specialty societies that have expressed concern over efforts to change the current Medicare rules regarding medical imaging. The College has offered to work with all specialties to draft a policy that reduces imaging overutilization and increases patient safety and image quality.
The policy under consideration by the College would restrict Medicare payments for the performance and interpretation of CT, MRI, and PET to accredited facilities that function under the supervision of a designated physician imager (DPI). A DPI would be a radiologist, or other physician satisfying appropriate training and experience requirements, who interprets clinical images produced in a certified facility. Services provided for the purpose of radiation therapy treatment planning and other therapeutic services will be exempted from this policy.
Specific principles of this policy include the certification of physicians and accreditation of imaging equipment and facilities by private organizations, such as the College, as determined by the Secretary of the Department of Health and Human Services. In addition to the physician qualifications, certified facilities must meet certain quality and operation standards, such as passing annual inspections by a qualified medical physicist and employing appropriately trained and licensed or certified nonphysician personnel to perform CT, MRI, or PET examinations.
In 2005 the ACR will continue to work closely with Congress and the appropriate federal agencies on the emerging details of this new policy. The ACR will keep its members informed as further developments dictate.
For further information, please contact ACR Director of Congressional Relations, Josh Cooper, at (800) 227-5463, ext 4308, or at joshuac@acr.org.