CMS Mandates Accreditation for Imaging Providers; Accrediting Organizations Named


Providers of a advanced diagnostic imaging services, including physicians, who bill for the technical component must become accredited by a designated accreditation organization by Jan. 1, 2012 in order to be reimbursed by Medicare, according to a notice from CMS published in the Federal Register. The notice approved three organizations to accredit advanced diagnostic imaging suppliers: the American College of Radiology, The Joint Commission, and the Intersocietal Accreditation Commission.

Pursuant to the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA), the Health and Human Services Secretary is required to designate accrediting organizations for suppliers furnishing the technical component of advanced diagnostic imaging services. Advanced diagnostic imaging services include CT, nuclear medicine, PET and MRIs. X-rays, ultrasound, fluoroscopy, and diagnostic and screening mammography are excluded from the definition of advanced diagnostic imaging services. The accreditation requirement applies to any supplier of the technical component of advanced diagnostic imaging services. Supplier is defined as "a physician or other practitioner, a facility, or other entity (other than a provider of services) that furnishes items or services under this title [42 USC 1395]." The notice does not provide guidance as to which entities, if any, may be excepted from the accreditation requirements.

While it is unclear what criteria the designated organizations will use for accrediting advanced diagnostic imaging suppliers, MIPPA provides that the criteria used by the accreditation organization shall include:

  • Standards for qualifications of non-physician medical personnel who furnish the technical component of the services.
  • Qualifications and responsibilities of medical directors and supervising physicians, such as training in advanced diagnostic imaging services in a residency program, expertise obtained through  experience or continuing medical education courses.
  • Procedures to ensure the safety of persons who furnish the technical component of advanced diagnostic imaging services and individuals to whom such services are furnished.
  • Procedures to ensure the reliability, clarity, and accuracy of the technical quality of diagnostic images produced by the supplier.
  • Procedures to assist the beneficiary in obtaining the beneficiary's imaging records on request.
  • Procedures to notify CMS of any changes to the modalities subsequent to the organization's accreditation decision.

The Joint Commission is expected to continue to use many of the same criteria it currently uses in accrediting diagnostic imaging centers, and will likely publish additional guidance and criteria early this year, according to a representative at The Joint Commission. Information on the Joint Commission's criteria for diagnostic imaging centers is available at this link. It is unclear whether the American College of Radiology and the Intersocietal Accreditation Commission will publish additional guidance as well.

For additional information, please contact Kim Harvey Looney, Seema Kanwar, or any member of Waller Lansden's Healthcare practice at 800-487-6380.

The opinions expressed in this bulletin are intended for general guidance only. They are not intended as recommendations for specific situations.  As always, readers should consult a qualified attorney for specific legal guidance.