Medicare providers face a reimbursement cut for procedures on non-compliant CT equipment
Back in 2014, the President signed the Protecting Access to Medicare Act (HR 4302). According to the Act, the Centers for Medicare & Medicaid Services (CMS) will reduce its reimbursements for certain diagnostic procedures performed on CT equipment that does not meet the NEMA XR-29 CT standard. Starting in 2016, the reimbursement penalty is 5 percent, but for 2017 and onwards, the penalty increases to 15 percent.
To avoid the reimbursement cut, an XR-29 compliant CT scanner needs four attributes designed to optimize, reduce, and document dose radiation without affecting the quality of diagnostic imaging. Many newer CT scanners, including some that we feature here at Providian Medical, already have the attributes necessary for XR-29 compliance.
Whether you’re wondering if your CT scanner is XR-29 compliant, you’re looking for a new or pre-owned CT scanner, or you’re considering an upgrade, we at Providian can help. In the meantime, you can find more information about the law and how it applies to you below.
What to Know About XR-29 Compliance
Medicare providers will not face a reimbursement penalty as long as their CT scanners follow the National Electrical Manufacturers Association (NEMA) XR-29 Standard Attributes on CT Equipment Related to Dose Optimization and Management.
And that’s sure a mouthful!
The simplified version is this — when Medicare patients receive an outpatient CT scan on a non-compliant scanner, the hospital/clinic/private medical imaging center will face a reimbursement reduction (5 percent in 2016; 15 percent in 2017 and onwards). The reason for this NEMA standard is increased patient safety and optimized radiation reduction.
Aside from the reimbursement cut, there’s no rush to frantically update your scanner(s) to meet XR-29 compliance. According to the Joint Commission, which accredits hospitals, there are no plans to require XR-29 compliance for accreditation.
Where Does this Law Apply?
The penalty for XR-29 non-compliance only affects the technical components of diagnostic CT scans billed in outpatient settings. The penalty does not apply to inpatient settings, including the settings at critical access hospitals.
If your facility, therefore, bills for inpatient and outpatient scans on the same scanner, the penalty only applies to scans billed as Medicare outpatient procedures.
In terms of the specific procedures, this law applies to diagnostic scans with the following CT procedure CPT codes:
- Any succeeding codes
These codes signify diagnostic CT procedures for the head, pelvis, abdomen, extremities, and so on. As such, the law doesn’t apply to CT stimulation or interventional radiology.
However, if you have PET/CT equipment, then the law only applies when using the PET/CT equipment for diagnostic CT exams that include any of the CPT codes listed above.
Is Your CT Scanner XR-29 Compliant?
For a CT scanner to be XR-29 compliant, and not receive penalties on Medicare reimbursements, the scanner needs those four attributes mentioned earlier.
The four attributes include:
- Automatic Exposure Control (AEC) — This is an operational mode on the CT scanner that optimizes the radiation output for specific body regions and parts. Manufacturers call the AEC feature by different names, such as:
- GE – Auto mA/ Smart mA
- Toshiba – SUREEXPOSURE
- Siemens – CareDose
- Philips – DoseRight
- Hitachi – Intelli EC
- Reference Adult and Pediatric Protocols — These include pre-loaded scanning parameters established to accomplish a particular clinical task. Generally, these protocols are displayed on the CT console and categorized by anatomical regions.
- CT DICOM Radiation Dose Structured Reporting (RDSR) — This feature captures both pre- and post-exam dose information in a standardized electronic format, which is then included in the patient record.
- DICOM RDSR also monitors and tracks doses to establish diagnostic reference levels, facility dose management, and quality assurance.
- For this feature to be XR-29 compliant, it must generate a structured report that conforms with the object definitions in the DICOM 2011 PS 3.3 standard.
- MITA Smart Dose Check — Prior to starting a scan, the MITA Smart Dose Check notifies and alerts CT operators that the estimated dose index is higher than the value set by the healthcare organization.For this feature to be compliant, it must alert CT operators before the scan.
- For the CT scanner to continue operation, the MITA Smart Dose Check often requires the CT operator to enter his/her name, a diagnostic reason for exceeding predetermined thresholds, and a reconfirmation of the chosen protocol. With some machines, the operator may also need to enter a password.
- If this feature is on your system, you should be able to find it on the CT’s console.
If you’re still unsure whether or not your CT system is compliant, you can ask the system’s OEM. In some cases, the OEM may install the necessary upgrades for free, and the FDA has encouraged all manufacturers to implement the four attributes as widely as possible.
XR-29 Compliance and Your Facility
Under the law, facilities will need to declare when CT procedures are performed with a non-compliant system.
If you’re performing selected CT procedures on a non-compliant system, you’ll have to include the modifier “CT” on claims for CT scans, which will result in the payment reduction for the CT service. If you do not report the CT modifier, then Medicare will pay the full amount, but once Medicare identifies the overpayment, your facility will be liable to a debt owed to the Federal Government.
Remember, having non-compliant CT scanners only affect your outpatient Medicare reimbursements by 15 percent (starting in 2017), and upgrading a CT scanner for XR-29 compliance might not be financially worth the cost. You are not forced to upgrade your scanner, and using non-compliant scanners will not result in being shut down or losing accreditation.
If you decide that an upgrade is necessary and you don’t want to take that 5-15 percent cut, then call Providian Medical today. Our specialized technicians can help you determine which features your CT scanner needs, and how you can make your scanner XR-29 compliant. We can also discuss the benefits of getting an XR-29 compliant CT scanner for your facility at a fraction of the cost of a new scanner.
To talk to one of our experts today, call Providian Medical at (877) 661-8224.