April 28, 2017

ACR Opposes CMS Proposal on Accreditation Survey Disclosures

The American College of Radiology (ACR) is expressing serious concerns about a recent Centers for Medicare & Medicaid (CMS) proposal to require public disclosure of accreditation survey results.

The CMS proposal is described in the Hospital Inpatient Prospective Payment Systems Proposed Rule. If adopted, it would establish a mechanism requiring Accrediting Organizations (AOs), including those that accredit suppliers of advanced diagnostic imaging, to make accreditation survey results and plans of corrective action (PoCs) publicly available on their websites.

Although the proposed policy arose out of concerns unrelated to imaging accreditation, CMS asserts it is “critical” for organizations that accredit advanced diagnostic imaging providers to “provide health care consumers with compliance information about Medicare-participating suppliers of advanced diagnostic imaging services.”

As an AO for advanced diagnostic imaging, the ACR has serious concerns with provisions that would require AOs to agree “to make all Medicare advanced diagnostic imaging final accreditation survey reports, as well as acceptable PoCs, publicly available on its website within 90 days after such information is made available to the supplier of advanced diagnostic imaging services for the most recent 3 years.”

The ACR believes that mandatory public reporting of accreditation results would discourage hospital imaging departments, which are currently not mandated to be accredited under the Medicare Improvements for Patients & Providers Act (MIPPA), from voluntarily participating in imaging accreditation. The ACR is likewise concerned that publicly posted survey results could be used in ways for which they were not intended, could mislead patients and could undermine the purpose of accreditation. The ACR intends to submit comments opposing this provision of the proposed rule.