1. MIPPA makes proposed IDTF requirements unnecessary
In its 2009 Proposed Medicare Fee Schedule, CMS has proposed that
physician practices be required to register each office where they per-
form any type of diagnostic testing (from phlebotomy to diagnostic
imaging) as an Independent Diagnostic Testing Facility (IDTF). The
original purpose of the IDTF rules was to provide quality standards for
non-physician providers, as CMS always assumed that physician provid-
ers already practiced quality care. CMS never has raised quality/safety
issues concerning cardiologists that would suggest the onerous IDTF
requirements are needed.
The Cardiology Advocacy Alliance (CAA) believes the proposed IDTF
requirements are unnecessary. The Medicare Improvement for Pa-
tients and Providers Act of 2008 (MIPPA) already requires accredi-
tation of labs that provide advanced diagnostic imaging services
(MRI, CT, and nuclear medicine/PET) by 2012 to receive full Medi-
care reimbursement. These accrediting organizations evaluate medi-
cal personnel, medical directors, supervising physicians, technologists,
equipment, safety procedures, and quality assurance programs. CAA
supports accreditation of labs as one mechanism that can help to en-
sure high-quality studies using trained technologists and physicians in
an appropriate environment with current, well-maintained technology.
CAA also supports the use of clinical appropriateness criteria and phy-
sician credentialing to ensure appropriate utilization of imaging ser-
vices. MIPPA requires a two-year demonstration study regarding the
use of appropriateness criteria for advanced diagnostic imaging ser-
vices by 2010. CAA believes that adherence to appropriateness criteria
as developed by specialty societies (e.g., the American College of
Cardiology) will help to ensure that all patients receive the appropri-
ate test for the appropriate reason at the appropriate time.
(continued on reverse)
CAA provides national leadership on legislation, policies and reimbursement
methodologies that affect cardiovascular patients’ quality of care,
Cardiology access to services and the stability of cardiovascular group practices.
Advocacy CAA represents the interests of more than 4,500 private practice physicians.
Alliance For more information, please visit our website: cardiologycaa.com
2. (continued from reverse)
If CMS implements IDTF requirements:
Practices will be prohibited from sharing equipment among offices.
This requirement will result in needless additional costs to the health
care system through duplication of equipment, and may limit access
to routine diagnostic services for patients in rural locations.
IDTF standards would require supervision by a physician who is skilled
in the performance and interpretation of each diagnostic test per-
formed. Many Medicare carriers have interpreted this standard as
requiring a radiologist. But most cardiology practices have physicians
with double- or triple-board certifications in their clinical sub-special-
ties. These physicians are highly qualified to perform and interpret
imaging studies to diagnose and treat cardiac disorders without assis-
tance by a radiologist. With due respect to radiologists, their participa-
tion would slow the patient care process without substantive quality
improvement since most radiologists do not specialize in cardiac disease.
The IDTF enrollment process is government bureaucracy at its worst.
IDTF enrollment requires a 40+-page written application and on-site
inspections. Since Medicare carriers have not received extra funding
for IDTF administration, application review and on-site inspections are
a low priority for these carriers. Given the large number of physician
offices that would be required to enroll as IDTFs, on-site inspections
likely would take much longer to complete than the current three- to
four-month waiting period. The proposed IDTF standards provide
that a physician practice could not bill and collect for diagnostic tests
until they receive their IDTF certification.
THE BOTTOM LINE: The CMS proposal to require IDTF enrollment for all
physician offices providing diagnostic tests in addition to the MIPPA ac-
creditation requirements would be unnecessarily burdensome and costly
to both physicians and the Medicare program, and would adversely af-
fect patients’ access to care. Accreditation by national accrediting bod-
ies as required by MIPPA is the better path for physician providers than
the proposed IDTF registration requirements.
For more information about CAA, please call 734.878.2108 or visit our website: cardiologycaa.com.