Timing Makes Accreditation a Top Priority
In 2008, the Medicare Improvements for Patients and Providers Act (MIPPA) was signed, calling for all providers of CT, MRI, breast MRI, nuclear medicine, and PET exams to be accredited through one of three organizations—the American College of Radiology (ACR), The Joint Commission, or the Intersocietal Accreditation Commission (IAC)—by January 1, 2012, in order to receive reimbursement for imaging services from the Centers for Medicare and Medicaid Services (CMS). Under MIPPA currently, only private outpatient facilities need to be accredited in such a fashion, but the legislative change will force all facilities that provide such services to become accredited in order to receive proper reimbursement.
The basic requirements for CMS reimbursement include personnel qualifications for facility staff, image quality, safety standards, equipment performance, and quality control. However, the accreditation process for the three accrediting bodies differs significantly. For example, accreditation through the IAC entails becoming accredited through one of its modality-specific branches: Intersocietal Commission for the Accreditation of Computed Tomography Laboratories (ICACTL) or Intersocietal Commission for the Accreditation of Nuclear Medicine Laboratories (ICANL), for instance. Meanwhile, accreditation through The Joint Commission is a more holistic accreditation of the entire facility, something not required by CMS, or undertaken by the IAC or ACR.
“We have had, in the past, only one of the pieces of equipment—our MRI—accredited through the American College of Radiology,” said Spiro Gerolimatos, MD, Bright Light Radiology, Elk Grove Village, Ill. “But we went with The Joint Commission accreditation this time. We wanted to go beyond the accreditation of individual pieces of equipment. We wanted to have the entire facility and our processes reviewed to see how we compare to qualitative standards of hospitals and other independent facilities; to have a pragmatic idea of where we are relative to our performance and our standards.”
MIPPA only requires facilities to become accredited through one of the accrediting bodies. However, as is the case with the IAC, each modality that the facility practices needs to be accredited individually.
“ICANL is for nuclear medicine and ICACTL is for CT,” said Ryan Wagley, RT(R)(N), staff technologist, Lake PET Imaging, Baton Rouge, La, which received accreditation in both modalities.
Understanding the Process
The process by which facilities become accredited also varies depending on the accrediting body. Despite their differences, though, each organization asks for the same CMS-required criteria outlined above. Other requirements include site visits, protocol and policy manuals, and quality control inspections.
“A lot of the paperwork and materials were done by my manager and include procedural manuals, policy manuals, and all the paperwork to make sure that we are complying with and have the internal structure that is appropriate for our employees, that this is a healthy environment, that there are no risk factors, and that privacy standards are complied with,” said Gerolimatos. “It was general facility compliance from the standpoint of our associates, the physical facility and environment, and the level of organization. That was all one component.”
Gerolimatos’ Joint Commission-accredited facility also had to undergo several other inspections. The owners of the facility had to meet with accrediting representatives to present their information. In addition, The Joint Commission spends time at each facility to trace patients and processes from pretreatment through discharge.
“The Joint Commission was physically present while patients were scanned or procedures were completed,” said Gerolimatos. “A patient came for a lumbar epidural injection, which is a somewhat invasive procedure that we provide. They interviewed the patient before the procedure, witnessed the form of consent, the setup of the trace and lab procedure, the procedure itself, postprocedural instructions, and postprocedural care until discharge.”
The application process for the IAC, which accredits specific modalities, is more intensive on an individual-machine basis. Lake PET Imaging recently became accredited in both CT and nuclear medicine and was asked to supply a bevy of technical specifications and paperwork.
“It’s an online application. We put in our staff and titles, credentials, and continuing education credits to prove that our personnel are legitimate,” said Wagley. “Then we described the equipment that we used: two scanners, both made by Siemens. I put in the model serial numbers as well as some technical specifications of the machine. Next, we go into protocols for imaging. The last component is our policy and procedures manual, including any patient preparation or patient follow-up. They also want to make sure that our doctors are reviewing each other, doing peer review once a week or once a month.”
Once accredited, however, Lake PET Imaging was chosen for a site visit to verify that the processes and protocols that they submitted were actively being practiced in the facility.
“One thing the representative said was, ‘We’re not here to tell you how to do things. We’re not the experts. You make up those policies.’ She was just there to make sure that we are actually doing what we said we were doing, not just pulling some information from a book and then doing our own thing,” said Wagley.
The length of the process also varies depending on which organization a facility chooses to pursue accreditation. Gerolimatos says that the accreditation process through The Joint Commission took approximately 6 months, while Wagley estimates the IAC process took upwards of 16 months. And as the January 2012 deadline approaches, the accrediting process is sure to slow because of an influx of applications.
Weighing Costs and Benefits
The cost of the process also varies between the IAC, The Joint Commission, and ACR, and needs to be taken into account.
“It cost a little less than $9,000,” said Gerolimatos about The Joint Commission accreditation. “It’s actually less expensive than the ACR accreditation because we were having the entire facility accredited rather than specific modalities, but I can’t remember the number precisely.”
“There was a fee, around $2,000 I believe,” said Wagley. “The IAC has different branches for each modality. Our site is a joint venture with Our Lady of the Lake Regional Medical Center; we are 30% owned by a group of doctors and the hospital owns 70% of this. It’s like an outpatient clinic but we do inpatient studies. Lake PET Imaging did the ICACTL accreditation, but for the nuclear part, the hospital has its own nuclear medicine department separate from the nuclear medicine we do here, so we included our nuclear application with the hospital’s. So they paid for that.”
Regardless of the length of the application process or eventual costs, however, come January 1, 2012, any facility that wishes to receive reimbursement for advanced imaging procedures needs to be accredited by the IAC, ACR, or The Joint Commission. And while revenue is the ultimate benefit, Gerolimatos believes that the process carries its own inherent benefits beyond those of CMS reimbursement.
“I think the chief benefit from the financial standpoint is the CMS reimbursement,” said Gerolimatos. “The other benefit is that you can put this accreditation in front of your facility, which carries some weight. The third thing was a self-check. We all think that we are the best. The question is what do other people who have specific criteria think about our methods, our actions, and our processes.”