On June 12, 2017 The American College of Radiology (ACR) submitted comments on the Inpatient Prospective Payment System (IPPS) in three significant areas:
- The use of the CT and MR cost centers
- Requirements for accrediting organizations (AOs) to post survey results and plans for corrections on their websites and
- Clinical decision support (CDS) as a means of reducing regulatory burden
Although the ACR does not typically comment on this rule, there is grave concern about how these issues might affect radiology practices in the hospital setting.
The ACR is very concerned that the Centers for Medicare and Medicaid Services (CMS) has been requiring hospitals to use specific CT and MR cost centers which are contributing to the use of flawed hospital data and thus causing continued decline in payments to hospitals for these services. The ACR made arguments and shared data as to why these cost centers no longer should be used and recommended that hospitals be allowed to return to the use of the general diagnostic radiology cost center and whichever type of cost allocations work best for them. This is standard practice for most other hospital departments, and no other cost centers exist that are equipment specific.
In addition, CMS has proposed that CMS-approved Accrediting Organizations (AO) for Advanced Diagnostic Imaging (ADI) be required to post-accredited facilities’ survey reports and acceptable Plans of Correction (PoCs) on AO's websites. The ACR expressed serious concern that the proposal would undermine the quality improvement functions of accreditation by discouraging honest and open communication, which is essential to identify any quality or safety issues that require improvement. The comments also noted that the proposal would fail in CMS’ underlying goal of improving transparency and providing a resource to consumers allowing them to compare quality at facilities. The ACR urged against CMS’ adoption of this proposed policy, noting that the public posting of the AO’s accreditation program requirements (along with the names of facilities that have met those program requirements) would provide more useful information to consumers.
Finally, CMS released a request for information (RFI) on ways to reduce burdens on providers and patients. The ACR advised CMS that the implementation of clinical decision support should not be considered a regulatory burden. Past Presidential budgets recommended that authorization programs by for-profit radiology benefit managers (RBMs) as a way to control advanced imaging of which was opposed by all physician stakeholders. Congress wisely chose to pursue an alternative utilization management policy by mandating the Medicare program to use physician developed AUC. The ACR assured CMS that this approach to address appropriate utilization of imaging is the most efficient, transparent and evidence-based approach moving forward.
To read more about the IPPS proposed rule and ACR’s comments, click here.