Imaging Services

The American Academy of Otolaryngology – Head and Neck Surgery recognizes the importance of quality standards and accreditation for medical imaging and knows that Academy members look to the foundation to provide leadership on this issue.  In response to these developments, the Academy has established the Imaging Committee. This committee, chaired by Gavin Setzen, MD, is charged with providing additional resources and training for continuing medical education in this area and with monitoring continuing legislative and reimbursement developments. Below are recent advocacy efforts related to reimbursement and coverage of CT imaging services.

Contact Jenna Kappel with any questions regarding health policy or payment issues related to CT imaging.
Contact Education with any questions regarding medical education related to CT imaging and the accreditation process.

Comparative Billing Reports Issued on Advanced Diagnostic Imaging (4/12/12)

Background
On Thursday, February 16, the Centers for Medicare & Medicaid Services (CMS) sent a national provider comparative billing report (CBR) to certain providers addressing their advanced diagnostic imaging use. CBRs, produced by Safeguard Services under contract with CMS, contain actual data-driven tables and graphs with an explanation of findings that compare a provider’s billing and payment patterns to those of their peers located in their state and across the nation. A maximum of 5,000 providers were selected per CBR topic including Advanced Diagnostic Imaging, Sleep Studies, Spinal Orthotics, and other categories.

Definition of Peer
CBRs were distributed by comparing physicians imaging utilization compared to their peers. According to the CBR website, "peer" is defined as any other provider other than radiologists, oncologists, and IDTFs, who has paid claims for advanced diagnostic imaging codes.

Academy Advocacy Efforts
In March, the Academy attended a meeting with CMS staff and at the meeting, the issue of reports came up. Staff talked with the CMS Deputy Director about the Academy's concerns regarding the lack of communication between CMS and societies like the Academy. We also have concerns regarding the definition used in the CBRs for "peer." The CMS Deputy Director expressed interest in talking with us further, so we expect to have more dialogue with CMS staff about this concern, as well as the definition of "peer" and where this effort may be leading.

CMS has indicated that CBRs are not intended to be punitive or sent as an indication of fraud, but are intended as a proactive statement that will help providers identify potential errors in their billing practice. However, the Academy is monitoring the effort as the reports may be part of future rulemaking processes for physician payment policy. If CMS does propose new policies, the Academy will advocate for members and will comment on any proposed policy that may impact Otolaryngology-head and neck surgeons.

In the CBR letters sent to providers, the June 2011 MedPAC report focusing on the billing of diagnostic imaging services and concerns with physician “self referral.” In this report, MedPAC recommended the establishment of a prior authorization program. The Academy urged the Congress to reject this recommendation and more information including the Academy’s letter to Congress can be found below.

What You Can Do if You Receive a Report
The Academy recommends members use the American College of Radiology’s (ACR) Appropriateness Criteria (see information below) to assist referring physicians in making the most appropriate imaging or treatment decisions for specific medical conditions. Information and comments from the Academy on Appropriateness Criteria can be found below. Once the AAO-HNSF’s Clinical consensus statement: CT Imaging Indications for Paranasal Sinus Disease is released in early summer 2012, this will also be a helpful resource for members.

Academy members that received CBRs are encouraged to contact their Carrier to discuss issues with the CBRs and their definition of "peer" at a local level. In the past, discussions with Carriers at a local level have been successful in explaining issues like this and changing the direction of the effort.

SafeGuard Services LLC, the company awarded the Comparative Billing Report (CBR) contract, has developed a website to address Frequently Asked Questions. This site can be found here.

If you have questions about your CBR, you can contact SafeGuard Services LLC at (530) 896-7080 or at www.cbrservices.com. If you have questions about your claims, please contact your Medicare Administrative Contractor. If you have received a CBR, please contact the Academy at healthpolicy@entnet.org and send us a copy of the CBR with all sensitive and confidential materials redacted so we can continue to monitor this situation.

AAO-HNSF Policy Statement on Imaging Studies Reimbursement

Academy Urges Congress to Reject MedPAC Recommendations on Imaging Services (7/20/2011)
The Academy as part of a coalition with the American Medical Association and several other specialty societies sent a letter to the members of the three Congressional Medicare authorizing committees and House and Senate leadership urging them to reject the Medicare Payment Advisory Commission’s (MedPAC) recommendations in its June 2011 report on Medicare’s payment policy for imaging services. One of MedPAC’s recommendations was for Medicare to require outlier physicians to participate in an advanced imaging pre-authorization program, which could negatively impact otolaryngologists. View the letter 

On August 27th, the Academy sent a letter to MedPAC Chairman, Glenn Hackbarth, J.D. to express concerns about the Commission's report on imaging services. View the letter

Academy Comments on ACR Appropriateness Criteria  (4/21/2011)
The Academy provided input on the American College of Radiology’s (ACR) Appropriateness Criteria. The ACR created these evidence based guidelines to assist referring physicians in making the most appropriate imaging or treatment decisions for specific medical conditions. We thank Gavin Setzen, MD, for leading this endeavor and also the Academy’s Imaging, Allergy, Asthma & Immunology, Equilibrium, Hearing, Pediatric Otolaryngology, Rhinology and Paranasal Sinus, and Skull Base Surgery committees. View the letter.  

NIA to Recognize ICACTL Accreditation of Advanced Imaging Services  (2/10/2011)
Due to our advocacy effort led by Gavin Setzen, MD, the National Imaging Associates (NIA) has agreed to recognize accreditation for advanced imaging from the Intersocietal Commission for the Accreditation of Computed Tomography Laboratories (ICACTL) from February 14, 2011. ICACTL is one of the three accreditation organizations that CMS has approved to certify advanced imaging services and is currently the only organization that accredits cone-beam CT scanners.View the letter

Advanced Imaging Accreditation

Providers who furnish the technical component (TC)  for advanced imaging services (MRI, PET, CT, and nuclear medicine imaging) must be accredited by January 1, 2012 by the:

• American College of Radiology (ACR)
• Intersocietal Accreditation Commission (IAC)
• The Joint Commission (TJC)

Learn more about the accreditation process

Bulletin articles on Imaging Services:

April 2011: Imaging Committee: Health Policy and Quality Updates

July 2011: Imaging Committee: Health Policy, Advocacy, and Quality Updates

Page last updated: April 12, 2012