Accreditation Claims Processing Update - May 2011

May 27, 2011

The SNM and other medical specialty groups have been working out the kinks regarding implementation by the Centers for Medicare and Medicaid Services (CMS) regarding accreditation as mandated by the ACA. During an open door forum call on May 17th, CMS announced it would ease provider requirements originally proposed and put a stronger emphasis on the organizations that accredit providers (e.g. ICANL, ACR or JCAHO), which would affect all practices billing for the technical component (TC) of advanced diagnostic imaging services. To be clear, this accreditation mandate does not apply to hospitals billing the technical component.

According to Sandra Bastinelli, an official with CMS’s Center for Program Integrity, CPT codes will no longer need to be entered for advanced imaging.  In addition, you will not have to enter the make and model information for equipment that has been used on the Medicare enrollment applications. “CMS will get this information from the three imaging accreditation bodies it chose to accredit Medicare providers,” said Bastinelli. “The CMS-855 forms and online PECOS will still be altered for the advanced imaging requirement, however the changes will come in the form of “checkboxes” that indicate whether you bill for the TC of advanced imaging services and whether you are accredited for advanced imaging.”

CMS is also cutting the new specialty designation – specialty code 95 (Advanced Diagnostic Imaging Accreditation) – that was designed to accompany the accreditation rule. “It is our hope that these improvements will make your transition smooth,” she added.

Following these changes, it is important to note that you must still be accredited by one of three accrediting organizations authorized by CMS on or before the January 1, 2012 deadline if you plan to continue to provide advanced imaging services in 2012. The three accrediting organizations are the American College of Radiology (ACR), the Intersocietal Accreditation Commission and The Joint Commission.  It is necessary to seek accreditation for advanced imaging if you bill for the TC of CT, MRI, PET or nuclear medicine imaging procedures in the Medicare physician fee schedule (MPFS).

Currently CMS has not released a timetable of when it will alter its 855 forms and online PECOS to reflect this latest change to advanced imaging accreditation.

Additionally, the SNM and other medical specialties including the accrediting bodies continue to work with CMS on some outstanding issues. Pending resolution are billing globally versus split billing the PC and TC, as well as what will happen with new providers. At present there is no provision for physicians that plan to begin services on or after January 1, 2012.

As we expect continued clarification and more changes, the SNM will provide updates on the web site so do check back. For now, focus on getting your facility accredited and stay tuned.