The American Hospital Association (AHA) has sent a comment letter to CMS urging the agency to suspend four new imaging efficiency measures it included in its final rule updating payment policies and rates for both hospital outpatient departments and ambulatory surgical centers for 2009. Under the rule, CMS is expanding its quality requirements by adding four imaging efficiency measures that hospital outpatient departments would be required to report in 2009, making a total of 11 reportable measures required to receive the full inflation update in 2010. In the letter, AHA emphasized that it has “serious concerns about these measures,” including that two are not based on medical evidence, and the process by which the measures were proposed, reviewed and adopted by CMS. You can view AHA’s letter here.