Under the Medicare Improvement for Patients and Providers Act of 2008 (MIPPA), all facilities that bill for advanced diagnostic imaging services under the technical component of part B of the Medicare Physician Fee Schedule must be accredited by a CMS-designated accrediting organization by January 1, 2012 to qualify for Medicare reimbursement. This rule affects providers of MRI, CT, PET and nuclear medicine imaging services for Medicare beneficiaries on an outpatient basis.
CMS has accepted and approved the ACR’s accreditation program requirements. The CMS final rule on MIPPA implementation states: “We did not propose any substantive standards that suppliers furnishing the TC of advanced imaging would have to meet. We have chosen to utilize clinical guidelines that are already accepted by the experienced accreditation organizations already performing accreditation.”
For accredited facilities that receive reimbursement from Medicare for the technical component of imaging examinations under the Fee Schedule there are additional mandatory requirements. As with all accreditation requirements, verification of compliance with these requirements will take place during any on site survey by the ACR or CMS.
Each facility must have a process in place for all patients to obtain copies of their records and images that is HIPAA compliant. Patients should be made aware of this process at the time of examination or if requested by the patient at a later date.
Each facility must have a procedure for documenting the qualifications of the facility’s personnel from the primary source when appropriate for licenses and certifications. Facilities must also verify that personnel are not included on the Office of Inspector General’s (OIG) exclusion list.
All facilities must make publicly available a notification for patients, family members or consumers that they may file a written complaint with the ACR.
While these procedures are mandatory only for facilities that receive reimbursement from Medicare for the technical component of imaging examinations under the Fee Schedule, the ACR encourages all facilities to implement such procedures.
MIPPA did not give authority to provide a "grace period" for new suppliers and the statute does not give CMS the authority to pay suppliers without active accreditation from one of the designated accreditation organizations. If an accredited facility expands its services by location or modality, the supplier will be given a 120 day CMS provisional extension to receive an accreditation decision for the respective location or modality.
To qualify for the 120 day CMS provisional, the CMS billing numbers entered into the accreditation application must match the CMS billing numbers of an existing ACR accredited facility that is under the same ownership. Otherwise, proof of ownership documentation (i.e., property lease agreements, partnership or business agreements, etc.) proving affiliation to an existing ACR accredited facility will be required.
For more information on MIPPA resources, visit CMS/MIPPA Resources.
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