Are you close to being XR-29 compliant?
If you squeaked out a “no,” you’re certainly not alone. Although the reimbursement rubber hit the road the first week of January, it’s estimated that about 35 to 40 percent of imaging providers don’t yet have all of their CT equipment on the right side of the NEMA Smart Dose Standard.
Optimizing and managing radiation dose according to the four-part XR-29 Standard is all part of the Centers for Medicare & Medicaid Services’ (CMS) march toward value-based health care. In its effort to drive reform, Medicare has cut reimbursements by 5 percent for each scan done on a non-compliant CT. The reimbursement cut triples, to 15 percent, starting Jan. 1, 2017.
For many of our customers, getting to a point of full compliance may mean expediting equipment upgrades, or even purchasing new imaging equipment. In addition to these financial considerations, XR-29 compliance also has implications and impact on clinical quality and communication with current and prospective patients.
For all of these reasons, and others, we advise that you don’t move forward until you take these four steps.
Step 1: Educate Yourself on the XR-29 Standard
Take the time to educate yourself on the NEMA Smart Dose Standard, also known as the MITA Smart Dose standard and the XR-29 Standard. While many of us have read an article or two (or three), there’s important detail in the official documentation that will be helpful as you level set your team for the changes to come.
The Medical Imaging & Technology Alliance (MITA) website is a great first stop. Not only is there important detail about the four attributes of CT scanners that make up the standard, there are resources ranging from Original Equipment Manufacturer (OEM) certification portal links to frequently asked questions (FAQs).
Step 2: Evaluate Your Current Equipment
When it comes time to take stock of your various pieces of imaging equipment and see how each of them, individually, measure up, you have several choices. The easiest course of action is a quick call to your CT manufacturer. Reach out to your account representative, or your assigned service engineer to get the ball rolling.
He or she can run down the items on our XR-29 checklist that makes it easy to see whether or not your equipment is considered compliant. The control panel of an XR-29-compliant CT system holds a wealth of information, as do the CT studies themselves. You’ll want to make sure that all your equipment has the four specific attributes included by the XR-29 Standard. Other features are great, but XR-29 is very specific in what constitutes compliance.
Step 3: Do the Math for Today – And Tomorrow
Wherever you are in your journey to XR-29 compliance, it’s important to think long-term. Right now, the hit on reimbursement only affects the technical component on diagnostic CT procedures billed for Medicare patients in outpatient settings. This includes imaging centers, physician offices and hospital outpatient setting under Medicare Physician Fee Schedule (MPFS) and the Hospital Outpatient Prospective Payment Systems (HOPPS).
The first-year penalty of 5 percent may not seem like much, but it does add up quickly, especially for a high-volume facility. When the reimbursement penalty increases to 15 percent in 2017, you’ll be talking about real money. The example reimbursement calculations in our XR-29 compliance white paper can help you communicate the financial impact on your organization.
If you’re a Critical Access Hospital or doing imaging in an inpatient setting, you’ve got a reprieve – at least for now. The XR-29 Standard, and reimbursement penalty for non-compliance, does not apply to scans done at CAHs and in hospital inpatient settings. That could change as the march toward value-based health care continues.
Step 4: Plan Your Work – And Work Your Plan
XR-29 compliance involves more than meeting a regulatory standard and upgrading equipment. At its heart, the NEMA Smart Dose Standard is about optimizing the dose of radiation that patients receive when they undergo diagnostic imaging scans.
By putting together a plan to become compliant, you’ll help your facility avoid any loss of reimbursement dollars and you’ll also help make health care safer for everyone.