MIPPA makes proposed IDTF requirements unnecessary


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MIPPA makes proposed IDTF requirements unnecessary

  1. 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. 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.