Health Care Legal Update

Accreditation Organizations for Advanced Diagnostic Imaging Providers

    Douglas S. Griswold

The Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) requires that suppliers furnishing the technical components of advanced diagnostic imaging services to Medicare beneficiaries must be accredited by an approved accreditation organization by January 1, 2012.  Suppliers include physicians, non-physician practitioners, and Independent Diagnostic Testing Facilities (IDTFs).  Advanced diagnostic imaging services include diagnostic magnetic resonance imaging (MRI), computed tomography (CT), and nuclear medicine imaging (including positron emission tomography (PET)).  Significantly, x-rays, ultrasound, fluoroscopy, and diagnostic and screening mammography are specifically excluded from this definition.

The Secretary of the United States Department of Health and Human Services has been authorized to designate certain organizations to serve as accrediting bodies.  Three national accreditation organizations to accredit advanced diagnostic imaging suppliers were recently approved:

American College of Radiology (ACR)
505 9th St. N.W.
Suite 910
Washington, DC 20004
202-223-1670

Intersocietal Accreditation Commission (IAC)
6021 University Boulevard, Suite 500
Ellicott City, MD 21043
800-838-2110

The Joint Commission
601 13th Street, NW
Suite 1150 N
Washington, DC 20005
202-783-6655

Each of these accreditation organizations will be required to enact quality standards that address the safety of the imaging equipment as well as the safety of the patients and staff.  While these quality standards have yet to be finalized, it is anticipated that the standards will focus on the following:

• The qualifications of the medical personnel (both physician and non-physician staff) and medical directors providing diagnostic imaging services
• The quality assurance and quality control programs adopted by imaging providers to ensure the safety, reliability, clarity, and accuracy of diagnostic imaging.

We anticipate that additional information regarding the accreditation standards will be made available over the coming weeks and months as each of the three accrediting organizations establishes their own set of quality standards.  In the meantime, we would advise imaging providers to begin gathering information regarding the qualifications of their imaging personnel and the quality of their imaging modalities in anticipation of the deadline.

If you have any questions about these new accreditation requirements, please do not hesitate to contact one of the members of our Health Care Section.