January 3, 2012

The Center for Medicare and Medicaid Services (“CMS”) adopted new accreditation requirements for providers of diagnostic images billing the technical component of such services earlier last year.  The new requirements, effective as of January 1, 2012, require that any supplier of images for the technical component only, be accredited, otherwise reimbursement will be denied and/or disallowed or recaptured.  CMS promulgated that it has approved three national accredited organizations to perform accreditation for all advanced diagnostic imaging providers billing for the technical component of any imaging services, as follows:  American College of Radiology, the Joint Commission, or the Intersocietal Accreditation Commission.  For more information visit:  http://www.cms.gov/transmittals/downloads/R380PI.pdf.

CMS policy states that No Suppliers are Exempt – and has explicitly confirmed that oral surgeons and dentists are required to obtain accreditation as well.  Furthermore, the accreditation requirement exists regardless of the type of entity and individual providing the TC.  Thus lay entities employing technicians to provide the technical component of diagnostic imaging services require accreditation as well.  Be advised that this accreditation requirement only applies to the TECHNICAL COMPONENT of diagnostic imaging, and as such to the supplier of the images. The physician interpreting the test (performing the Professional Component) is not required to be accredited.

If this requirement applies to you, you should already be accredited or well on your way, because accreditation can be a lengthy process.  If this is first you are hearing of this requirement, we recommend you take immediate steps to remedy your situation.  Without accreditation CMS will have just cause for denying reimbursement.  Bottom line:  CMS’s playing field, CMS’s rules.

Copyright © 2012 by Kirschenbaum & Kirschenbaum PC.

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