by John W. Mitchell
, Senior Correspondent | July 09, 2015
From the July 2015 issue of HealthCare Business News magazine
This regulation was created when President Obama signed the Protecting Access to Medicare Act of 2014 on April 1, 2014 (Section 218). According to Wayne Webster, principal at Proactics Consulting, the XR-29 regulation applies only to Medicare patients in an outpatient setting.
“There is no requirement to meet the XR-29 standard beyond the reduction in Medicare reimbursement,” said Webster. “Upgrading or replacing a non-compliant CT scanner is an option. But most are waiting to analyze the impact on revenue from the reduction in Medicare reimbursement.” He adds that the new regulations do not apply to inpatient units or non-Medicare patients. And he said the regulation offers no technical, measurable standard to demonstrate the reduction in CT dose. Webster projects $360,000 in Medicare CT revenues will result in a loss of $18,000 in 2016 with the 5 percent cut, and a loss of $54,000 in 2017 under the 15 percent reduction for noncompliance with XR-29.
According to a white paper published by the Medical Imaging & Technology Alliance (MITA), the law requires providers to report any CT scan that is not compliant with XR-29 smart dose standards. The white paper explained that providers will most likely be required to provide documentation from the equipment manufacturer to identify whether a machine is compliant or not.
“A decision to upgrade non-compliant CT equipment should take into consideration many factors, such as complexity of your equipment, your clinical usage and ultimately the cost/benefit of upgrading,” states the MITA white paper. Manatee Diagnostic’s Graham doesn’t have a dog in the XR-29 fight. He has or is in the process of upgrading all of the center’s CTs. But philosophically, he doesn’t think penalties are the way to bring about change. “I think it works better to get accrediting organizations like The Joint Commission to implement appropriate government safety regulations,” he said. “In order to assess penalties, you have to really make sure the proper investigation is done.”
Other issues Mabry says to note are the delay of the implementation of ICD- 10 and the fact that the Medicare Advisory Commission that informs Congress continues to recommend that Medicare move to a single payment regardless of site of service (hospitals versus freestanding centers).
“These are significant developments and it’s not clear, exactly, how some of these changes will impact imaging operations,” Mabry says. “The change to the merit-based payments is a good example. It will affect all physicians, but it’s a one-size-fits-all approach that may not translate well to radiologists and could put them at risk for payment cuts. It may mean significant reduction in radiology compensation. The system may work better if it compares data specifically to a radiologist peer group.” He also predicts that the new pricing transparency will be a big issue for hospitals, whose charges traditionally run higher than outpatient imaging centers.