Over the past few months, I’ve had many members ask me about these new dose requirements. The "doc fix" legislation (Protecting Access to Medicare Act) earlier this year included many implications for imaging, among which were new regulations on radiation dose management.
Here’s what you need to know.
Providers will need to meet four requirements
The provisions of the law follow those outlined in the National Electrical Manufacturers Association (NEMA)’s report XR 29-2013.
The report, Standard Attributes on CT Equipment Related to Dose Optimization and Management, was published by NEMA’s Medical Imaging & Technology Alliance (MITA), and is sometimes referred to as simply MITA Smart Dose. It introduces four new standards:
- DICOM Radiation Dose Structured Reporting (RDSR): enables capturing of dose information in the standardized patient record
- Dose check feature: follows the Computed Tomography Dose Check standard and alerts technologists before the scan if the estimated dose index exceeds an established threshold
- Automatic exposure control (AEC): automatically adjusts radiation dose during the scan to adjust for the differences in radiation diffusion between different organs
- Reference adult and pediatric protocols: pre-loaded parameters on a CT scanner used to standardize scan execution
For more details, check out NEMA’s original announcement or the full report. I would also recommend connecting with your CT vendors, as they can be fantastic resources for information and implementation support.
Providers who don’t meet them will be penalized
Starting in January 2016, Medicare will reduce reimbursement by 5% for CT scans acquired on technology that does not meet the new standards. In 2017, that number will increase to 15%.
These penalties will apply to the technical fee for any exam under the Medicare Physician Fee Schedule or the Hospital Outpatient Prospective Payment System.
But there's no reason to panic
Two things to keep in mind are that providers have some time to meet these standards and that meeting them may not be as hard as you think.
First, these penalties won’t go into effect for over a year, and we will have the chance to see an update on XR 29 implementation in the FY 2016 Proposed Rule next year. So, we don’t have to scramble to meet these standards immediately.
Second, many members I’ve spoken with are surprised to learn that they already meet some or all of the requirements. In fact, MITA estimates that about 25% of CT systems meet the XR 29 standard and about 40% can meet them with a straightforward software upgrade.
According to Gail Rodriguez, executive director of MITA, “These are not burdensome requirements…only very old equipment will have difficulty being (or be unable to be) upgraded. It’s really just the old, antiquated equipment that has to go.” In other words, organizations with advanced technology should have no problem meeting these requirements.
However, for institutions with older scanners, or with many scanners in need of software upgrades, I would recommend starting the planning process now so you can make necessary investments ahead of January 2016.