On May 24, 2011, the Centers for Medicare and Medicaid Services (CMS) posted 10 new FAQs related to Advanced Diagnostic Imaging Accreditation. Section 135(a) of the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) required the Secretary to designate organizations to accredit suppliers that furnish the technical component (TC) of advanced diagnostic imaging services. Such services include diagnostic magnetic resonance imaging, computed tomography, and nuclear medicine imaging such as positron emission tomography. Pursuant to 42 C.F.R. § 414.68, by January 1, 2012, suppliers, including but not limited to physicians, non-physician practitioners and Independent Diagnostic Testing facilities that furnish the TC of advanced diagnostic imaging services for Medicare beneficiaries are required to be accredited.
The recent CMS FAQs related to the Advanced Diagnostic Imaging Accreditation includes discussion of the following:
- The accreditation rule does not apply to hospitals.
- Although the accreditation requirement only applies to the suppliers producing the images themselves, all interpreting physicians must meet the accreditation organizations’ published standards for qualifications and responsibilities of medical directors and supervising physicians (i.e., requirements related to residency program training and continuing medical education).
- If entities would like to supply the TC after the January 1, 2012 accreditation deadline, they must be accredited at the time that they apply for Medicare enrollment.
- The designated accreditation organization will transmit its findings to CMS or its contractor when its decision becomes final.
- MIPPA excludes from the accreditation requirement x-ray, ultrasound, and fluoroscopy procedures, as well as diagnostic and screening mammography which are subject to quality oversight by the FDA.
- If a supplier is accredited before January 1, 2010 by one of the designated accreditation organizations, it must apply for re-accreditation within the timeframe specified by the accreditation organization instead of meeting the January 1, 2012 deadline.
- After submission of a completed application, and depending on the complexity of the organization (i.e., number of locations), the average time to become accredited is generally four to five months.
- The three national accreditation organizations approved by CMS include the American College of Radiology, the Intersocietal Accreditation Commission and The Joint Commission.