On January 1, 2016, computed tomography (CT) equipment not in compliance with all four attributes of the XR-29 Standard will be subject to a 5 percent per scan reduction. The reduction will increase to 15 percent on January 1, 2017.
The National Electrical Manufacturers Association (NEMA) XR-29 standard (MITA Smart Dose) specifies four attributes of CT scanners that “contribute to or help perform optimization and or management of doses of ionizing radiation while still enabling the system to deliver the diagnostic image quality needed by the physician.” CT scanners meeting the XR-29 Standard have the following: DICOM-compliant radiation dose structured reporting (NEMA XR 29-2013); dose check features (NEMA XR 25-2010); automatic exposure control (NEMA XR-28-2013); and reference adult and pediatric protocols (NEMA XR-28-2013).
All CT scanners within a facility used for applicable CT examinations will need to comply with XR-29 in order to receive full reimbursement. This penalty applies only to the technical component of the following diagnostic CT procedure CPT® codes:
- 70450–70498
- 71250–71275
- 72125–72133
- 72191–72194
- 73200–73206
- 73700–73706
- 74150–74178
- 74261–74263
- 75571–75574
The law does not apply to interventional radiology procedures, CT simulation for radiation therapy or positron emission tomography (PET)/CT (unless the PET/CT scanner is used for diagnostic CT studies and includes any of the CPT® codes listed above).
The ACR, in response to the Medicare Physician Fee Schedule and Hospital Out-Patient Prospective Payment System proposed rules respectfully requested in its September 8 and August 31 comment letters that CMS delay enforcement of the XR-29 related penalty for 12 months until January 2, 2017, to allow adequate time for CMS to notify providers of their final implementation expectations and to allow software vendors and providers to implement necessary software coding changes. The ACR also suggested that CMS work closely with the ACR, RBMA, AHRA, AAPM and MITA on a means of systematic implementation that ensures appropriate reimbursement for these CT claims. The Final Rule is due out shortly and will address whether CMS will delay implementation until 2017.
See the American College of Radiology NEMA XR-29 (MITA Smart Dose) Standard: Frequently Asked Questions for more details.