In accordance with Section 135 (a) of the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA), suppliers providing the technical component of advanced diagnostic imaging (ADI) services that are paid under the Medicare Physician Fee Schedule must become accredited by January 1, 2012 in order to continue providing these services to Medicare beneficiaries. The accreditation process applies to suppliers, including but not limited to, physicians, non-physician practitioners, and IDTFs who provide the technical component for MRI, CT, nuclear medicine imaging, or PET procedures. MIPPA expressly excludes from the accreditation requirement x-ray, ultrasound, and fluoroscopy procedures, as well as diagnostic and screening mammography. Also, the accreditation process does not apply to hospitals.
CMS has approved the following three national accreditation organizations to complete the accreditation process of ADI suppliers:
• The American College of Radiology (ACR)
• Intersocietal Accreditation Commission (IAC)
• The Joint Commission (TJC)
CMS did not standardize the accreditation process, meaning the manner and price of accreditation may vary between each accreditation organization. Although there are no set standards put forth by CMS, the main areas targeted are:
• Personnel qualifications for non-physician medical staff, medical directors, and supervising physicians
• Image quality
• Equipment performance
• Safety standards for staff and patients
• Quality assurance and quality control
This process can take up to five months, and potentially longer. Contractors will begin denying claims with the denial code N290 for services on or after January 1, 2012 for modalities that are not accredited. Suppliers that have billed for ADI services within the last six months should have received a letter, similar to this one, from their Medicare contractor informing them of the new accreditation requirements.
Click here for a complete summary of a Listening Session on the accreditation process hosted by CMS on March 22, 2011 written by Thomas Greeson of ReedSmith LLP.
ADVOCATE will continue to keep you updated on any new information that becomes available.
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