The new law will undoubtedly be abbreviated as MIPPA. At first glance, of most importance to physicians is the fact that MIPPA prevented (at least temporarily), the proposed physician pay-cuts planned for Medicare, and enacted a 0.5 percent increase in Medicare rates. This was a good thing for doctors. However, the bill covers many more important issues in its 103 pages.
Of particular importance to any physicians who perform diagnostic imaging is section 135 of MIPPA. The provision, beginning on p. 39 of the bill, establishes that, beginning Jan. 1, 2012, any entity that performs diagnostic imaging services (including a physicians office) and that wishes to receive a Medicare facility fee for the performance of those services will be required to have received accreditation from a national accrediting agency approved by Medicare.
In short, when a Medicare patient undergoes a diagnostic imaging procedure, Medicare pays the performing entity a technical component, often referred to as the “facility fee.” In addition, Medicare also reimburses a “professional fee,” which pays the radiologist or other provider for reviewing and interpreting the diagnostic study. Thus, Medicare pays two fees, a facility fee and a physician fee; after 2012, the facility fee will be contingent on the facility’s being accredited.
Medicare has not yet developed a list of approved accreditation organizations. It is likely that entities like the Joint Commission, the Accreditation Association for Ambulatory Health Care (AAAHC), and others will be authorized to perform this type of accreditation when CMS approves specific organizations to perform the accreditation.
The MIPPA provision is not an isolated incident: Recently there has been significant attention by the federal government on the fact that Medicare expenditures for diagnostic imaging services have risen dramatically over the past five to 10 years. Some argue that too many diagnostic tests are being performed, while others say that newer technology is allowing more people to undergo diagnostic imaging that has historically not been available to them. This debate was spotlighted in a recent GAO report. It remains to be seen which argument is “right” or which is “wrong,” but the proper answer probably lies somewhere in between.
Dr. Pliura (tom.pliura@illinoisastc.com) is the founder and CEO of zChart. Learn more about zChart.
