Any physician or medical group practice, non-physician practitioner, certain health care facilities and organizations (each a “supplier”) that provides the technical component of “advanced diagnostic imaging services” must become accredited by an accreditation organization designated by the Secretary (the “Secretary”) of the U.S. Department of Health and Human Services (“HHS”) in order to submit a claim for payment under the Medicare Program. This accreditation requirement does not apply to hospitals, skilled nursing facilities, home health agencies and other hospital-based providers of advanced diagnostic imaging services. Under 42 U.S.C. 1395m(e), “advanced diagnostic imaging services” include diagnostic MRI, C/T, PET and other nuclear medicine services and other imaging and computer-assisted imaging services, but specifically exclude x-ray, ultrasound, fluoroscopy and diagnostic and screening mammography services. Under this new accreditation requirement, the term “physician” includes doctors of medicine or osteopathy, doctors of dental surgery or dental medicine, podiatrists, optometrists and chiropractors.
The Secretary and the Centers for Medicare and Medicaid Services (“CMS”) announced on January 26, 2010 their approval of the following organizations to accredit suppliers of advanced diagnostic imaging services: (1) the American College of Radiology, (2) the Intersocietal Accreditation Commission, and (3) the Joint Commission.
Each supplier of the technical component of advanced diagnostic imaging services must become fully accredited by one of these three recognized accrediting organizations by January 1, 2012. Each accrediting organization establishes its own standards for evaluating each covered supplier. However, 42 U.S.C. 1395m(e) requires each accrediting organization to include the following criteria as part of their evaluation of a supplier:
(1) standards for qualifications of non-physician personnel who furnish the technical component of advanced diagnostic imaging services;
(2) specific standards for qualifications and responsibilities of medical directors and supervising physicians;
(3) procedures to ensure that the supplier’s equipment meets performance specifications;
(4) standards that require the supplier to ensure the safety of the persons who furnish the technical component and the patients for whom such services are furnished; and
(5) the establishment and maintenance of a quality assurance and quality control program by supplier that ensures the reliability, clarity and accuracy of the technical quality of diagnostic images produced by the supplier.
For all practitioners and covered facilities that furnish advanced diagnostic imaging services, we recommend that you review your arrangements regarding these services well in advance of the January 1, 2012 effective date to begin the accreditation process.
