Following up on the effects of the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA), a report from the Government Accountability Office (GAO) stated that a decline in advanced imaging services in recent years was likely driven by factors other than accreditation requirements.
While these other factors, such as reduced Medicare payments for certain CT and MRI services, make it hard to pin down the exact impact of the accreditation mandate contained within MIPPA, interviews with imaging providers suggested the effect of accreditation on access was limited, according to the GAO.
MIPPA requires that providers who supply Medicare-covered advanced diagnostic imaging services in office settings be accredited by CMS-approved organizations. The law also mandated that the GAO issue a report to examine the effect of this accreditation requirement on Medicare beneficiary access to advanced imaging services.
To this end, the GAO used claims data to find trends in the number of imaging services provided to Medicare beneficiaries both before and after the accreditation mandate took effect in January 2012.
Results showed that the number of relevant advanced imaging services provided to Medicare beneficiaries declined at similar rates before and after MIPPA took effect, suggesting other factors were contributing to the decline.
“The effect of accreditation on access—as illustrated by our analysis of the trends in [advanced diagnostic imaging] services in the office setting—is unclear in the context of recent policy and payment changes as well as other factors affecting the use of imaging services,” read the report. “In particular, the decline in [advanced diagnostic imaging] services occurred amid the implementation in recent years of public and private policies to slow rapid increases in imaging utilization and spending.” Factors that may have played a role in the decline of imaging services include payment reductions, the growth of prior authorization and radiation awareness initiatives.
Report authors interviewed representatives from the Intersocietal Accreditation Commission (IAC) and the American College of Radiology (ACR)—two accrediting organizations that together account for 99 percent of all accredited imaging providers—as well as a number of providers from various regions. The interviews suggested that while the accreditation process likely didn’t have a large impact on access relative to other recent policies, new providers run into the issue of offering services without Medicare reimbursement for up to six months while they complete the accreditation process.
IAC and ACR representatives requested that CMS offer a provisional accreditation period for new providers that would allow them to receive reimbursement during this process, but the GAO report noted that CMS has said it does not have the authority under MIPPA to provide provisional accreditation.