With its passage of the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA), Congress took key steps to ensure the quality of imaging services provided in physicians' offices and other outpatient facilities reimbursed under Medicare Part B. Most notably, by January 1, 2012, suppliers seeking reimbursement for advanced diagnostic imaging services under the Medicare Part B Physician Fee Schedule must be accredited by an organization approved by the Centers for Medicare & Medicaid Services (CMS). On January 26, 2010, CMS issued a notice naming the American College of Radiology, the Intersocietal Accreditation Commission and The Joint Commission as the approved organizations from which providers can obtain accreditation.

While the accreditation requirement governs only the technical component of advanced diagnostic imaging services, it applies to an array of suppliers, including physicians, non-physician practitioners, and physician and non-physician organizations. Importantly, the accreditation requirements do not apply to a physician's professional interpretation of the images. Imaging services governed by the accreditation requirements include MRI, CT, nuclear medicine and PET. The MIPPA expressly excludes x-rays, ultrasound and fluoroscopy procedures from the accreditation requirements. Diagnostic and screening mammography services, which are subject to oversight by the Food and Drug Administration, are also excluded.

Suppliers who were accredited by one of the three approved accreditation organizations as of January 1, 2010, need not seek re-accreditation. However, those providers who are not currently accredited should begin the accreditation process as soon as possible in order to ensure accreditation by the deadline.