Ready or not, it’s coming. CMS pre-published the 2016 rules for Hospital Outpatient Payments and Physician Fee Schedule. These rules will be formally published on Nov. 13 and Nov. 16, respectively. Despite numerous requests, CMS has decided not to delay the implementation of XR-29, and so effective January 1, 2016, CT operators will have to use a specific Code Modifier to report CT scans that were performed with CT scanners that do not comply with the XR-29 “Smart Dose” Standard. Beyond the burden of reporting, facilities will also face the financial hardship of 5% reduction in payments for scans performed on non-compliant systems.
If all this is making you a little anxious about your situation, consider the following two points before talking to administration and making decisions you may ultimately regret.
1. Know you’re not alone.
Feeling the time crunch? Wondering if it is just you who is not ready? A recent site survey by the Association of Medical Imaging Management (AHRA) shows that of about 500 facilities surveyed, 56% are not fully compliant and therefore could be subject to the 5% penalty in 2016. And the 15% penalty in 2017.
2. Analyze the problem
There are two issues at hand. First is the potential loss of income resulting from using non-compliant CT scanners. These penalties may not add up as high as you think if compliance with XR-29 is reached at some point in 2016. Take the time to consider your procedure volume and what 5% for 2016 really means for you.
The second issue is the requirement for using a new code modifier which depends on the scanner that was used, not the procedure that was performed. This may be quite challenging.
3. Consider the options.
There’s definitely not enough time before January 1, and likely not enough in the budget, to purchase and implement a new XR-29 compliant CT scanner. This is where 3rd party solutions may be your best option.
What to look for:
How do you select the right system and what are the right questions to ask? Several vendors offer add-on systems that promise XR-29 compliance. This is obviously a significant purchase, so do your due diligence, and carefully check several key factors when evaluating such 3rd party solutions:
- Does the proposed solution have (or will it soon have) FDA-clearance? Some providers may claim FDA clearance is not required. This claim is NOT supported by the CMS or FDA.
- Does the proposed solution full comply with all XR-29 requirements? Some solutions offer only partial relief (which will probably not pass accreditation testing). The most challenging requirement that you want to make sure you can meet is the need to stop the scan, PRIOR to the scan, in case the estimated dose levels exceed pre-defined values.
According to the pre-published rules, testing for compliance with XR-29 will be done as part of the periodic accreditation of the CT scanners. Implementing a solution that is not FDA-cleared and does not meet ALL XR-29 requirements, may result in failing the accreditation test and losing the money invested in an inadequate XR-29 solution.
So now what? Be informed. And make sure you select the right partner. I on behalf of Medic Vision, I invite you to visit with us at the coming RSNA 2015 meeting in Chicago (Hall A #3703). We can help advise you through XR-29, and share with you our approach and solutions for XR-29 compliance.