October 5, 2012
SNMMI Submits Letter to GAO Regarding Quality
On October 5, 2012, the Society of Nuclear Medicine and Molecular Imaging submitted a letter to the U.S. Government Accountability Office (GAO) regarding their document entitled "Questions for Selected Experts in Medical Imaging On Accreditation for Advanced Diagnostic Imaging Suppliers." Please find SNMMI's comment letter below.
The questions provided in the GAO document are:
Please briefly explain your organization’s role and expertise related to advanced diagnostic imaging (ADI) services, including whether it represents individuals who order, perform, and/or interpret ADI services.
Please describe your organization’s relationship, if any, with each of the three CMS-designated accrediting organizations for ADI suppliers. Please include whether your organization provided input on the accreditation standards used by each organization.
In your opinion, should there be specific minimum national standards established for suppliers providing ADI services to Medicare beneficiaries? Please respond yes or no and provide a rationale for your response.
Please briefly describe the minimum standards you would expect, if any, for accreditation of ADI suppliers in each of the following categories.
In your opinion, to what extent is there a consensus on standards for ADI suppliers? Would other experts in the industry generally agree with the standards you listed above?
In your opinion, should accrediting organizations be required to perform the following activities in order to grant accreditation to an ADI supplier? Please respond yes or no and provide a rationale for your response.
In general, how effective are current CMS requirements for ADI accreditation in ensuring the safety and quality of ADI services? What improvements, if any, could be made?
How do you define “high quality” and “low quality” ADI services?
Please provide examples of deficiencies that could be indicators of low quality ADI services, including:
* Deficiencies that could compromise the quality of images.
* Deficiencies that could constitute serious safety or health issues, such as those that could
jeopardize the health or safety of supplier staff or Medicare beneficiaries, or could constitute a
significant hazard to public health.
The U.S. Food and Drug Administration (FDA) has developed quality standards for mammograms that are much more specific than CMS’s requirements for ADI services.
* Please describe the key differences between mammograms and ADI services, such as the
technical difficulty of the procedures and the levels of radiation used.
* Can you describe reasons, if any, that standards for mammograms should be more specific
than standards for ADI services?