Q&A: MIPPA spells accreditation changes for outpatient practices
Leonard Lucey, legal counsel and senior director for non-breast imaging accreditation in the department of quality and safety at the American College of Radiology.
The Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) updates accreditation requirements for private outpatient facilities and is requiring accreditation by Jan. 1, 2012. The American College of Radiology (ACR) has been received an increasing numbers of questions about the process and its requirements. Health Imaging News spoke with Leonard Lucey, the ACR's legal counsel and senior director for non-breast imaging accreditation for quality and safety, to brush up on the details about MIPPA/Centers for Medicare & Medicaid Services accreditation.

HIN: Can you provide an overview of accreditation requirements?
Lucey: The MIPPA legislation outlines certain criteria for imaging accreditation for four specific modalities: nuclear medicine, PET, CT and MRI (which includes breast MRI) for providers who bill under Medicare Part B, for the technical component only. There has been some confusion because the legislation excludes hospitals, some of whom do provide outpatient imaging services. In these instances, we apply a simple rule of thumb. If the organization bills for imaging under Medicare Part B then it is subject to the new requirements. If it’s billed under anything else the new accreditation requirements don’t apply.

HIN: Do the new accreditation requirements differ from previous requirements?
Lucey: MIPPA accreditation differs from accreditation such as accreditation for mammography in that the law lists only generally the requirements suppliers or providers must meet; qualifications for staff that perform imaging--the technologists and the physicists who service the equipment, and general requirements for physicians who supervise the imaging operation, plus equipment performance specifications, safety standards for staff and patients and quality assurance and quality control programs.

HIN: How should sites process prepare for accreditation process?
Lucey: The law requires accreditation by January 1, 2012. According to the law and CMS’s interpretation of the law, facilities that are not accredited by that date cannot be reimbursed by CMS for the technical component of those services. There is no provisional or under review status. We strongly encourage facilities that are not accredited but need to be to apply as soon as possible but no later than July 1 to be sure that they get into the system.

HIN: Can you offer any suggestions for ensuring a streamlined process?
Lucey: There are three issues that applicants need to be aware of. First, one person should be in charge of the application and should completely understand all aspects of the application and the materials that need to be gathered. Second, the facility should very carefully follow the instructions. The majority of sites that have a problem with the application process or that take longer are those that have not followed instructions. Finally, the submission of clinical images should be reviewed and approved by a physician.

The critical point is to avoid procrastination. The quicker a facility complies with the accreditation requirements the quicker it gets into the system and attains accreditation. In addition, if an application is returned with a deficiency it is critical to get the information back to us as quickly as possible.

HIN: How long does the accreditation process take?
Lucey: ACR accreditation takes about 90 days once clinical and phantom images have been submitted for review, which may be 45 to 60 days from the time the application has been submitted.

HIN: Are there any final modifications that facilities should be aware of?
Lucey: There are some new requirements that CMS has imposed that must be met going forward even by facilities that already are accredited. Most of these are requirements for written policies such as policies on how to handle consumer complaints. Facilities must post a notice in the patient waiting area informing patients that they have a right to file a complaint with the accrediting body. Facilities also will be required to verify staff credentials. For example, facilities now need original source verification of certification from the certifying body such as the American Board of Radiology.