If this is your first time reading about XR-29, you may want to take a look at our other blogs on the topic first and come back.
- NEMA Standard XR-29 for CT- What Does It Mean for You?
- Is My CT Scanner XR-29 Compliant?
- Does NEMA Standard XR-29 Apply to PET/CT?
- Does Your Facility Need Iterative Reconstruction?
If you've been keeping track of what NEMA standard XR-29 could mean for your CT scanning facility, we've got some new details for you that will help clarify exactly what effect the standard will have on your reimbursements (if any).
What's New with XR-29?
As you know, and we'll quote ourselves from a previous article here, "Beginning in 2016, Medicare will pay less for certain diagnostic CT scans performed on CT equipment that does not meet the XR-29 CT standard (MITA Smart Dose) ." What was unclear at the time this statement was published was the full meaning of "certain diagnostic CT scans". What we now know is that the way a scan is billed will have just as much to do with whether or not it will be cut as its actual HCPCS code.
The ACR clarifies this in the October 10, 2014 issue of Advocacy in Action eNews, saying the reimbursement cuts in 2016 and 2017 will be applied to, "diagnostic CT procedures billed in physician office and hospital outpatient settings". The operative word here is outpatient.
The same publication goes on to further clarify saying, "If a facility bills for both inpatient and outpatient CT scans on the same scanner, the reduction only applies to those scans billed as outpatient procedures. The MITA SmartDose policy does not affect scans billed under the hospital inpatient setting or for interventional radiology procedures."
We later reached out to the ACR for any further comments regarding details and/or implications of implementing and verifying XR-29 compliance. Their latest official statement is, “The American College of Radiology (ACR) is aware that the Protecting Access to Medicare Act of 2014 (PAMA) contains language relating to safety and quality CT dose and requirements under NEMA Standard XR-29-2013. However, the Centers for Medicare and Medicaid Services (CMS), the agency responsible for overseeing the attestation of compliance of the NEMA Standard by providers has not provided guidance to accrediting bodies on implementation of a verification process. The ACR will take appropriate action when CMS guidance is announced. “
With this additional information, XR-29 becomes a little less inclusive and a little less intimidating, especially for hospitals. If your facility has multiple CTs that do not meet XR-29, this detail might allow you to continue scanning at full capacity and maintaining accreditation while taking the upgrade process on a more incremental basis. You may even be able to hold onto an older system and designate it for inpatient studies only. In any case, the more details on XR-29 emerge, the more hospitals and imaging centers will learn what their options might be.
If you know you need an upgrade, now is the time to begin your purchasing conversation. You have time to spare, and it's better to keep it that way. If you're not sure yet, it still can't hurt to begin weighing your options. Contact us to discuss the possibilities and check back at this page for future updates.