CMS solicits input on imaging data reporting program

In a meeting held January 31, the U.S. Centers for Medicare and Medicaid Services (CMS) solicited input on whether to add new imaging exams to a data reporting program designed to track imaging efficiency. Radiology was there to share its opinion -- including a suggestion that CMS look more closely at physician self-referral.

"CMS is thinking in terms of improving the quality of healthcare that individuals receive, improving the health of the overall population, and lowering healthcare costs by improving quality, not necessarily cutting services," Michael Rapp, MD, director of the Quality Measurement and Health Assessment group, told attendees. "We want to identify and measure the extent to which imaging is not efficiently used, and therefore help improve the quality of healthcare overall."

Despite the importance of tracking the quality and safety of outpatient imaging services, few national standards address variations in the delivery of services, define the quality of outpatient care, or measure its volume, the agency said.

To promote the efficient use of hospital outpatient imaging, the agency developed its Outpatient Imaging Efficiency (OIE) measures. The first four measures began to be publicly reported in July 2010; the calendar year 2011 final Outpatient Hospital Prospective Payment System (OPPS) rule published in November 2010 introduced three more measures for 2012 payment determination.

Not just utilization metrics

The American College of Radiology (ACR) of Reston, VA, and other attendees suggested a number of new measures for CMS' consideration, including pulmonary CT imaging for patients at low risk for pulmonary embolism and appropriate head CT imaging for adult mild traumatic brain injury. But the college also suggested the agency consider imaging efficiency from a different perspective, said ACR's director of metrics, Judy Burleson.

"We suggested CMS consider measures that aren't necessarily based on utilization metrics, which is what they're primarily using now," she said. "We suggested looking also at measures that are geared toward quality and safety of imaging, such as hospitals' participation in a systematic national dose registry. We feel that patient safety measures like this would affect larger numbers of patients."

Meeting attendees recommended that CMS develop its imaging efficiency program using the broader perspective of the diagnosis of particular disease conditions rather than basing its measures on procedures alone, and ACR had a specific suggestion, Burleson said.

"We suggest CMS develop measures for appropriate follow-up CT for incidental pulmonary nodules, as well as suggesting measures that look at more specific aspects of imaging quality, similar to what the Image Gently program calls for," she said.

In addition to expanding its perspective on efficiency measures, attendees asked CMS to also consider physician self-referral as an obstacle to imaging efficiency.

"Repeated studies have shown that self-referral causes a four- to seven-times increase in studies ordered," said Edward Petrella, MD, a radiologist at South Jersey Radiology Associates in Voorhees, NJ. "One self-referral issue is when physicians use the in-office exemption to order studies -- essentially allowing them to print money. A second issue is when hospital-employed physicians send their work to high-cost facilities, when high-quality, low-cost facilities are available in community."

For the session, CMS had asked attendees to suggest other data sources besides Medicare claims -- such as electronic health records -- that could be used to develop imaging efficiency measures.

"There are some registries already in place that could potentially be used as data sources," Burleson said. "But national electronic health records aren't far enough along yet nationally to be used for this kind of thing."

By Kate Madden Yee
AuntMinnie.com staff writer
February 1, 2011

Related Reading

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CMS issues MPFS conversion update, January 4, 2011

CMS posts final MPFS, HOPPS rules for 2011, November 12, 2010

CMS proposes 2.15% increase in HOPPS, July 14, 2010

CMS pitches 90% use rate in proposed 2010 MPFS rule, July 1, 2009

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