Impact on DXA Testing is Unclear.
On June 30, 2008 CMS proposed new rules that may have far-reaching implications for physicians providing diagnostic imaging services, including central DXA, to Medicare beneficiaries in their offices. CMS-1403-P would require physicians providing these services in a non-facility setting to comply with regulations that already apply to Independent Diagnostic Testing Facilities (IDTFs).1
The CMS proposed rule would require physicians performing diagnostic imaging services in their offices to:
- Enroll as an IDTF;
- Undergo inspection by the Medicare carrier;
- Ensure the licensure and/or certification of non-physician personnel such as technologists; and
- Have a supervising physician who must be proficient in the performance and interpretation of each type of diagnostic procedure. The proficiency may be documented by certification in a specific medical specialty or subspecialties or by criteria established by the Medicare carrier.
It is unclear how this proposal would be interpreted by local Medicare carriers and how it would affect physicians and technologists providing DXA testing. Carriers have interpreted the IDTF regulations in a very restrictive manner by requiring that most imaging procedures be supervised by a radiologist. The proposed rule would also impose minimum standards on technologists if the imaging procedure is performed in a state that does not regulate radiologic technologists.
CMS has requested comments and feedback regarding this proposed rule. The rule specifically requests comments by individuals and groups to respond to the following questions:
- Should the new requirements only apply to advanced imaging services such as PET, CT and MRI, and exclude X-ray, DXA, ultrasound and fluoroscopy?
- Should the new requirements apply only to imaging services or to other diagnostic testing services such as electrocardiograms?
- What should the appropriate criteria be for application of the new requirements?
These questions make it clear that the parameters of the proposed rule have not yet been finalized. ISCD will submit comments to CMS on the proposed rule by the August 28 deadline and will keep you posted regarding its status. As soon as ISCD has thoroughly analyzed the CMS proposal and developed our response, we will call upon our members to submit comments to CMS by the August 28 deadline. If you have questions or want to provide feedback on this issue, please contact ISCD Legislative Counsel, Donna Fiorentino.
1 IDTFs by definition provide diagnostic testing in a location other than a hospital or physician’s office, cannot bill for therapeutic or interventional radiology procedures and must provide at least one general supervision physician, who is on the premises and immediately available and is responsible for overall direction and quality control of the testing.
Last modified: December 27, 2012