Healthcare Chronicles
Healthcare Chronicles: The Joint Commission Discusses Accreditation for Advanced Imaging Services
April 15, 2010
by Michael Kulczycki
This report originally appeared in the March 2010 issue of DOTmed Business News
The Centers for Medicare and Medicaid Services (CMS) is now mandating the accreditation of freestanding imaging centers or medical practices for providers that bill for Medicare Part B under the technical component of the Physician Fee Schedule (PFS) for CT, MRI and nuclear medicine services by Jan. 1, 2012. This includes radiation oncology practices that employ PET and other nuclear medicine equipment.
The move to mandate accreditation by CMS is largely in response to many reports over the years, including the agency's own research data, on U.S. imaging providers and advanced imaging use. CMS wants to make sure that Medicare beneficiaries are receiving appropriate and quality imaging services. Accreditation is one way to ensure that. The cost of health care and the equipment utilization rate is also a concern and these modalities in particular have come under scrutiny.
CMS has announced the organizations that are now authorized to perform this accreditation. The Joint Commission is one of those designated, in addition to the American College of Radiology (ACR) and the Intersocietal Accreditation Commission (IAC). It is not a requirement to achieve accreditation by more than one of these bodies, but some organizations do. It is important to note that this mandate explicitly excludes hospital-based imaging or any facility billing under the Hospital Outpatient Prospective Payment System (OPPS). There are two distinct charges when billing for imaging services. The technical component involves the actual use of the machine, whereas the professional component is the reading or evaluation conducted by the physician. This mandate only pertains to providers who bill under the technical component of the PFS. Important exclusions include traditional X-ray, ultrasound, fluoroscopy and mammography. Accreditation for the latter has already been mandated under the Mammography Quality Standards Act (MQSA).
CMS has made very clear that they expect an on-site survey as part of the accreditation process. This is consistent with how The Joint Commission conducts its evaluation, but that will mean a change for ACR and IAC, neither of which currently requires an onsite evaluation. The other important thing to know is that both the initial survey and the resurvey are to be totally unannounced. That was news to us, but The Joint Commission has had lots of experience working with ambulatory providers in an unannounced survey format. We've been conducting unannounced surveys since 2006 and we haven't really seen any immediate challenges with our providers.
The financial impact of accreditation on rural providers is also a concern. The Joint Commission's fee structure is based on the annual volume of imaging services that are being rendered. For example, the cost for a small rural provider would be significantly less than a very large imaging provider. Another key characteristic of our process is that fees are billed over the length of the three-year accreditation period. This can help spread the cost and could reduce upfront expenses, especially for rural providers. CMS is cognizant of The Joint Commission's philosophy on accreditation, which is not modality or equipment-specific to qualification and image quality. Rather, The Joint Commission is systems-oriented and takes a global approach to both patient and staff safety.
Michael Kulczycki is the executive director for the Ambulatory Care Accreditation Program at The Joint Commission. He has more than 35 years of experience in managing and marketing health care organizations and other entities, and has spoken in numerous imaging center forums, including GE Healthcare's OIC Conference, ASC/Imaging 100, AHRA and RBMA.
This report originally appeared in the March 2010 issue of DOTmed Business News
The Centers for Medicare and Medicaid Services (CMS) is now mandating the accreditation of freestanding imaging centers or medical practices for providers that bill for Medicare Part B under the technical component of the Physician Fee Schedule (PFS) for CT, MRI and nuclear medicine services by Jan. 1, 2012. This includes radiation oncology practices that employ PET and other nuclear medicine equipment.
The move to mandate accreditation by CMS is largely in response to many reports over the years, including the agency's own research data, on U.S. imaging providers and advanced imaging use. CMS wants to make sure that Medicare beneficiaries are receiving appropriate and quality imaging services. Accreditation is one way to ensure that. The cost of health care and the equipment utilization rate is also a concern and these modalities in particular have come under scrutiny.
CMS has announced the organizations that are now authorized to perform this accreditation. The Joint Commission is one of those designated, in addition to the American College of Radiology (ACR) and the Intersocietal Accreditation Commission (IAC). It is not a requirement to achieve accreditation by more than one of these bodies, but some organizations do. It is important to note that this mandate explicitly excludes hospital-based imaging or any facility billing under the Hospital Outpatient Prospective Payment System (OPPS). There are two distinct charges when billing for imaging services. The technical component involves the actual use of the machine, whereas the professional component is the reading or evaluation conducted by the physician. This mandate only pertains to providers who bill under the technical component of the PFS. Important exclusions include traditional X-ray, ultrasound, fluoroscopy and mammography. Accreditation for the latter has already been mandated under the Mammography Quality Standards Act (MQSA).
CMS has made very clear that they expect an on-site survey as part of the accreditation process. This is consistent with how The Joint Commission conducts its evaluation, but that will mean a change for ACR and IAC, neither of which currently requires an onsite evaluation. The other important thing to know is that both the initial survey and the resurvey are to be totally unannounced. That was news to us, but The Joint Commission has had lots of experience working with ambulatory providers in an unannounced survey format. We've been conducting unannounced surveys since 2006 and we haven't really seen any immediate challenges with our providers.
The financial impact of accreditation on rural providers is also a concern. The Joint Commission's fee structure is based on the annual volume of imaging services that are being rendered. For example, the cost for a small rural provider would be significantly less than a very large imaging provider. Another key characteristic of our process is that fees are billed over the length of the three-year accreditation period. This can help spread the cost and could reduce upfront expenses, especially for rural providers. CMS is cognizant of The Joint Commission's philosophy on accreditation, which is not modality or equipment-specific to qualification and image quality. Rather, The Joint Commission is systems-oriented and takes a global approach to both patient and staff safety.
Michael Kulczycki is the executive director for the Ambulatory Care Accreditation Program at The Joint Commission. He has more than 35 years of experience in managing and marketing health care organizations and other entities, and has spoken in numerous imaging center forums, including GE Healthcare's OIC Conference, ASC/Imaging 100, AHRA and RBMA.