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UPDATE: Proposed Grace Period for MIPPA Accreditation

Posted by Adam Desjardins

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Nov 7, 2011 11:08:00 PM

:: 1 minute read ::

Here is an update on the proposed grace period for MIPPA’s mandatory accreditation for Advanced Diagnostic Imaging (ADI) providers. If this is news to you, check out this great MIPPA accreditation summary by the Block Team. The accreditation requirement basically says that if you are a physician or facility (other than a hospital), and you do CT, MRI, PET or Nuclear studies, you must be accredited by January 1, 2012 in order to continue receiving Medicare reimbursements.


The rule is simple. Imaging centers must be accredited to get reimbursements. However, as often happens in legislation, Congress failed to look at the consequences of rule in the real world.  How is that, you ask? Well what happens when a brand new center opens up? The center will not yet be accredited, and therefore, they’ll not be eligible for reimbursements! Without reimbursements, the new center will likely be a closed center!


congressman jim renacci MIPPA accreditation ammendmentBut here comes Congressman James B. Renacci and H.R 3328.  His proposed amendment to the MIPPA accreditation requirement would add a grace period for new imaging centers to gain accreditation, allowing them to receive reimbursements during the grace period. The grace period can be up to six (6) months. Here is how the grace period is calculated:

The grace period starts when the new physician or facility submits images for the accreditation process and ends when:

  • Accreditation is approved or denied OR
  • After 6 months have elapsed

During this grace period, a center would be able to receive reimbursements.  However, as the amendment is currently written, if the center fails to get accredited by the end of the grace period, and they have received reimbursements, the reimbursements would have to be paid back.


I should stress that this is NOT part of the law yet. The amendment is still in the legislative process, more specifically, it has been referred to committee. You can keep track of its progress here. If the legislative process is a fuzzy blur from civics class, here is a sophisticated treatise on the legislative process. Oh, Yes!

As always, feel free to contact me or follow the Block Blog to keep up to date on major news effecting the medical imaging world. We'd like to thank Joe Palmisano of Captive Radiology for bringing this latest update to our attention!

 mippa accreditation grace period    mippa accreditation reimbursement dollars at risk

MIPPA/CMS Equipment Accreditation Adds New Grace Period for Purchases


MIPPA Accreditation Deadline Looming… Your Reimbursement $’s at Risk?


Written by Adam Desjardins

author of blog post

Adam Desjardins is General Counsel at Block Imaging, representing the company in negotiation, contract review, and litigation. Adam works out of San Diego, CA where he lives with his wife and son. He spends his free time remodeling his home and tinkering with his ’67 Ford Mustang.

Topics: Medical Imaging News, Medical Imaging Equipment Price, Medical Imaging Equipment Cost

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