MIPPA Accreditation Requirements for Providers of Advanced Diagnostic Imaging Take Effect: How Do Otolaryngologists Rate?

Gavin Setzen, MD  Jenna Minton, Esq. Beginning January 1, 2012, the accreditation requirements outlined in the 2008 Medicare Improvement for Patients and Providers Act (MIPPA) took effect. This legislation requires that all nonhospital-based providers of the technical component of advanced diagnostic imaging procedures (nuclear medicine, CT, and MR) obtain accreditation from one of three accrediting bodies in order to be reimbursed for these services by Medicare. The three accreditation organizations approved by the Centers for Medicare & Medicaid Services (CMS) are the Intersocietal Accreditation Commission (IAC), the Joint Commission, and the American College of Radiology. Providers who were enrolled in Medicare prior to January 1, 2012, that have not obtained accreditation by January 1 will begin seeing claims denied this month. CMS, along with the accreditation organizations and Congress, have been troubleshooting ways to avoid unintended consequences to new Medicare providers who join the Medicare program after the January 1, 2012, start date, recognizing it will take them time to obtain the necessary accreditation as a new Medicare provider. The Academy will continue to monitor any policy changes that would impact new providers entering the field and apprise members of any changes. Otolaryngologists Receive High Marks The Academy views the accreditation process as an important initiative and recently reached out to the IAC’s accrediting organization for CT procedures, ICACTL, to see how our membership was responding to these new requirements. ICACTL reported that otolaryngologists have been extremely proactive in meeting the 2012 accreditation requirements. In fact, in 2011 ICACTL received the most applications ever in its history in a single year (311) and of those, the majority (71 percent) were from otolaryngology practices! The Academy applauds the membership for this wonderful achievement and is pleased that our membership is leading the way to achieve the highest quality of care in their practices. Likewise, we encourage those who are not yet accredited to contact one of the approved accreditation organizations listed above to begin the accreditation process immediately. Additional information can be found on their websites: Intersocietal Accreditation Commission http://www.icactl.org/icactl/index.htm The Joint Commission http://www.jointcommission.org/accreditation/accreditation_main.aspx The American College of Radiology http://www.acr.org/accreditation.aspx Accreditation Important for Your Patients, Practice In support of the ongoing accreditation efforts by practices, as chair of the AAO-HNS Imaging Committee, I have articulated the critical importance of becoming accredited. Specifically, during the past several years point-of-care imaging has grown in response to such factors as patient convenience, the availability of prompt clinical diagnosis and treatment, and low radiation CT imaging equipment suitable for an office setting. As such, the Academy strongly believes in the provision of high quality comprehensive care to otolaryngology patients and maintains that point-of-care imaging represents a modality of service that is in line with the Institute of Medicine’s six dimensions of high quality care: care that is safe, timely, effective, efficient, equitable, and patient-centered. The benefits to point-of-care imaging are extensive. Patient convenience means prompt diagnosis and treatment, and fewer trips to a medical center or doctor’s office. This results in lower costs to the patient and the health plan. In addition, office-based imaging provides significantly less time away from work for the patient. Time away from work reduces employee productivity, which, in turn, negatively affects their employers, often the very entity responsible for premium payments. Further, accreditation helps to ensure standardization of CT imaging with a strong focus on quality and patient safety, including avoiding unnecessary CT testing, recommending steps to eliminate avoidable exposure to radiation, and using dose-reduction protocols, in promoting the principle of “as low as reasonably achievable” (ALARA), an important contemporary principle in CT imaging. The Academy urges any members who have already obtained accreditation to email the health policy department at healthpolicy@entnet.org in the event they encounter claims processing issues or denial of payment due to processing errors linked to the designation of their accreditation status on the Medicare claims form. In addition, we encourage members to get more involved and participate in the in-person meeting of the Imaging Committee this fall during the annual meeting September in Washington, DC.