On August 27, 2008 the ISCD filed comments on the latest Medicare proposed rule, CMS-1403-P. The rule included several provisions that threaten our ability to care for osteoporosis patients. In addition to the administrative burden on physicians, the adoption of this proposed rule represents another assault on the availability of quality DXA.
The ISCD argued against the adoption of a new rule that would require physicians performing diagnostic imaging in their offices to enroll as an independent diagnostic testing facility (IDTF) and comply with certain standards in order to be eligible for reimbursement. The proposed rule in part focused on the qualifications for both physician and non-physician personnel performing these imaging procedures. CMS indicated that the impetus for this proposal was the result of comments by personnel at IDTFs who bristled under new requirements that only applied to imaging procedures performed in their facilities. They argued that regulations applying to imaging procedures should apply across the board regardless of where the location of physician performing it.
When implementing the rule on IDTFs, a majority of Medicare carriers require the supervising physician for DXA scans be limited to radiologists and/or internists. In addition, a majority of these carriers have not recognized the ISCD Certification of technologists. We argued that the rule would exclude a substantial and highly skilled portion of the provider community.
ISCD also opposed the inadequate reimbursement rate for DXA and urged CMS to reevaluate the reimbursement for DXA to more accurately reflect the cost of providing the service.
Last modified: December 27, 2012