Q. We perform CT, Nuclear Stress Tests, Echocardiograms and Ultrasounds. Do we need to be credentialed in all of these procedures?
In terms of whether your laboratory is required to be accredited in each modality for reimbursement would depend upon the state in which the studies are being performed, if they are Medicare studies especially starting in 2012, and currently which private insurers with which your laboratory participates. As noted during the webinars, each IAC division's website contains a section titled Reimbursement, where all policies of which we are currently aware are published.
Q. Is there an easy way to find out which private insurance companies require accreditation for ultrasound in Florida?
The Reimbursement sections of the ICAVL and ICAEL websites contain the reimbursement policies that we are currently aware of, for both Medicare and private carriers. As explained during the webinar, it is likely that additional policies exist of which the IAC is not aware. The IAC encourages providers to send us documentation of payment policies requiring accreditation and once confirmed, they are published on our applicable websites, as a service to the imaging providers.
Q. Can applicants use the ICACTL Standards for Technical Director, Medical Director, and safety processes to create our own documentation? Should applicants keep such written policies on file? Should specific names of Medical and Technical Directors be included in the policies or is it OK to simply include the title, stating that our organization will maintain such positions?
The ICACTL program is laboratory specific and guidelines are outlined in the standards for patient and personnel safety. The Standards describe policies that are required such as patient preparation, equipment quality assurance, contrast and medication supervision, and patient confidentiality. The facility must then develop policies and procedures that reflect their own practices. A copy of these policies must be submitted with the application and kept at the facility. You do not have to specifically name the personnel in the policy, but should indicate the responsible staff position such as the medical or technical director, service engineer, physicist, etc.
A list of the required policies and procedures can be found on the ICACTL website at www.icactl.org/icactl/pdfs/ICACTL_Policies_and_Procedures.pdf.
There are also several excellent general lab protocols on the ICANL web site, at www.icanl.org/icanl/apply/sampledocs.htm.
Here is the list of policies and procedure that are required, as well as other documentation:
- Contrast Administration/Supervision Policy
- Patient and Personnel Safety Policy
- Patient Pregnancy Screening/Testing Policy
- Patient Pre-Test Preparation Policy
- Medication and Contrast Administration Policy
- Acute Medical Emergency Policy
- Patient Confidentiality Policy
- Patient Identification Policy
- Preliminary Report Policy (if generated)
- Quality Assurance Tests:
- Acceptance Test (at installation or after major upgrade)
- Annual Survey (performed by a medical physicist or qualified expert)
- Two months daily/periodic quality control tests
- The Technical Quality Assessment Policy
- Image quality must be assessed
- Patient dose must be assessed
- Administrative function should be assessed
- The Interpretive QA Policy
- Includes peer review and correlation
- The Logs, Records or Reports use in the Technical and Interpretive QA
- Imaging Protocols
Applicant laboratories must designate Medical and Technical Directors that meet one of the training and experience pathways as outlined in the ICACTL Standards. The staff must indicate in the application which pathway applies and sign the letter of attestation in the application verifying their training and experience. Their name must be included in the application. The Personnel ICACTL requirements are located on the website, at www.icactl.org/icactl/pdfs/ICACTLStds_PartIFinal07.pdf.
Q. For a QC meeting, do the individuals have to meet all together at the same time and place, or can an informational letter with questions and answers be provided (i.e., for those small practices that only have a few individuals involved)?
To ensure compliance with each of the IAC division’s standards regarding Quality Assurance/Improvement, please refer to the Quality Assurance/Improvement section of the division Standards published on each website. In general QA is best utilized when shared in a group where it can be discussed, rather than through a written report. If multiple sites are involved, the use of web-based calls can be useful for participation from multiple locations.
Q. Our MRI facility is already accredited by the ICAMRL. I understand that we need to renew our accreditation every 3 years. Will ICAMRL notify me when I am due and what will be involved with renewal?
Yes, for the ICAMRL accreditation process as well as each IAC division, letters are sent to the attention of the Medical and Technical Directors one year from the date that the reaccreditation application is due for submission. A follow-up reminder postcard is then sent six months prior to the date the application is due. The reaccreditation application is the same as the original application, however you will be able to update the sections according to the changes that have occurred with your laboratory and also submit all new case studies.
Q. What constitutes an audit of a laboratory?
The answer to this question varies depending upon the type of IAC accreditation that you are inquiring about (i.e.: ICAVL, ICAEL, ICANL, ICAMRL and ICACTL). For example, the ICAEL randomly audits a percentage of the applications received each quarter and requires only that select group to submit the applicable documents such as licenses and certain policies. The selected laboratories are given 45 days to return the required attachments for review. Alternatively, as part of the ICANL accreditation process, all applicant laboratories are either selected to receive a site visit or required to submit specified policies and supporting documentation for an audit. Those laboratories selected for the audit are provided with an audit form to be completed, signed and returned to the ICANL office, inclusive of specified attachments, within 45 days. The required questions and attachments contain many of the same details reviewed during the site visit and include aspects that are not part of the application. Laboratories selected for the audit process are required to provide data and submit attachments related to structure and organization, procedures and protocols and quality improvement. As a new initiative slated to begin in early 2010, the IAC has plans for each of the five accrediting divisions to incorporate an audit of all accredited laboratories at some point during the three year accreditation cycle. There will be various types of documentation required and some laboratories will also be required to submit cases or reports to document ongoing compliance with the Standards. Details of this new audit program will be released at the end of 2009 for all IAC divisions.
Q. Please clarify whether or not hospitals must obtain accreditation for outpatient nuclear medicine imaging for CMS.
If you are asking about the Medicare Improvements for Patients and Providers Act of 2008 (H.R. 6331), MIPPA, it is the IAC’s understanding that this law will impact advanced diagnostic imaging services, inclusive of Nuclear Medicine, MR, CT, and PET that are provided in physicians offices and outpatient imaging centers that bill Medicare Part B.
Q. In Nuclear Medicine/Nuclear Cardiology, is the requirement of dual head camera mandatory or recommended, and by what date?
Currently, we are not aware of any payment policies that require a laboratory to scan using a dual head camera. A few years ago, Care Core, a radiology benefits management company, had a requirement for dual head cameras to perform nuclear cardiology studies but the policy was rescinded. You are advised to closely review any new payment polices published to be certain such a requirement is not included. The ICANL does not require a dual head camera for accreditation.
Q. As manager of a cardiovascular lab, I do not receive any email blasts. How can I go about getting on the list to receive email blasts?
Please provide your contact information utilizing the following link:
www.intersocietal.org/iac/mailinglist_iac.htm.
Q. With MIPPA, do you foresee any significant changes to the ICAVL Standards?
Currently, MIPPA only pertains to providers of “advanced diagnostic imaging procedures” which are defined as Nuclear Medicine, MR, CT, and PET, and therefore the ICAVL Standards would not be impacted.
Q. Is there an online option to verify our various accreditations?
Yes, each of the IAC divisions websites contain a link titled "ICA__L Accredited Laboratories." For instance, for echocardiography you can view the ICAEL Accredited Laboratories link at www.icael.org/icael/laboratories/labs.htm and access the laboratories by state, viewing the name of the laboratory, address, type of accreditation(s) granted and the expiration date of the accreditation. In addition, laboratories have the option of providing their website which can be included in this directory of accredited laboratories.
Q. I understand it is no longer required for cardiologists to renew their board certifications, therefore this issue is in review at our hospital. Will this be an issue with the IAC?
Each one of the IAC divisions has specific requirements for all medical staff and some such as ICANL do require board certification. You are advised to carefully review the requirements for qualifications of the medical director and medical staff for each IAC division that is applicable to your practice.
Q. What do you mean when you mention 'Administrative' quality?
Administrative Quality are those indicators generally used to assess and improve the administrative quality of the facility’s operation. The areas that may be assessed include, but are not limited to, such items as:
i. Appropriateness of procedures
ii. Scheduling back logs
iii. Patient wait times
iv. Accuracy of patient information during scheduling
v. Late reports
vi. Time from completion of procedure to distribution of final report
vii. Patient satisfaction
viii. Referring physician satisfaction
Q. Are all technicians required to be certified for Echocardiography and Vascular studies?
Both the ICAVL and the ICAEL Standards require the Technical Director to hold an appropriate credential.
As published in the ICAEL Standards: “The Technical Director must have an appropriate credential in echocardiography from the American Registry of Diagnostic Medical Sonography (ARDMS) or Cardiovascular Credentialing International (CCI).”
As published in the ICAVL Standards: The Technical Director must have an appropriate credential in vascular testing. Appropriate credentials include: Registered
Vascular Technologist (RVT); Registered Vascular Specialist (RVS); Registered Technologist Vascular Sonography [RT(VS)]; if applying
for visceral vascular only Registered Diagnostic Medical Sonographer
in Abdomen [RDMS (AB)]; for physician Technical Directors
performing only Extracranial and/or Intracranial testing, the American
Society of Neuroimaging’s certificate in Neurosonology.”
While the additional technical staff members are strongly encouraged to hold an appropriate credential, they have other options for demonstrating that they hold an appropriate level of training and experience.
Q. Are any other insurance companies other than UnitedHealthcare requiring accreditation for Echo and Vascular at this time?
The Reimbursement sections of the ICAEL and ICAVL websites contain the reimbursement policies that we are aware of, for both Medicare and private carriers. As explained during the webinar, it is likely that additional policies exist of which the IAC is not aware. The IAC encourages providers to send us documentation of payment policies requiring accreditation as once confirmed, they are published on our applicable websites, as a service to the imaging providers.
Q. Regarding UnitedHealthcare and Mobile Echo: if the mobile is accredited, can the office they serve bill on the 1500?
UnitedHealthcare is tracking labs that meet the accreditation requirements by address. In order to be in compliance, the address of the mobile site must be included in the application and on file with the IAC division. More specific questions should be addressed to UnitedHealthcare.
Q. Has Medicare estimated a date when accreditation must be completed for hospitals?
If you your question is related to the Medicare Improvements for Patients and Providers Act of 2008 (H.R. 6331), MIPPA, for now we are only aware that it will impact advanced diagnostic imaging services, inclusive of Nuclear Medicine, MR, CT, and PET that are provided in physicians offiices and outpatient imaging centers that bill Medicare Part B.
Q. Please clarify that accreditation for reimbursement is only required for outpatient services.
Many payment policies were discussed and reviewed during the webinar and vary depending on the type of imaging they cover, the state in which the procedure is performed, etc. Some of the policies discussed, such as UnitedHealthcare and MIPPA, do only cover procedures performed in physicians offices and outpatient imaging centers; however there are Medicare policies in place which cover Part A: hospitals for both echocardiography and vascular.
Q. For departments applying for reaccreditation, will the online process require us to start from scratch?
If you are applying for reaccreditation and using the online application for the first time, much of your initial application data will be present when you log in and it will be necessary to edit that information.
Q. Have you seen an increase in the number of accreditation applications for MR?
Both an increase in payment policies and an overall concern with documenting quality have resulted in vast increases in the numbers of applications submitted for each of the IAC accreditation programs.
Q. We are currently accredited in Echo. If we had another modality (i.e., carotids), what is the time frame for acquiring the ICAVL accreditation?
From the ICAVL standpoint, you may submit at any time your application is ready (as explained during the webinar, we no longer have quarterly deadlines and instead applications are accepted at any time throughout the year). If you are asking to be in compliance with a specific reimbursement policy, the answer is dependent upon the state in which the studies are performed and whether you are asking about Medicare studies or those reimbursed by private insurers.
Q. What does the patient incident report need to include for the MR application?
The incident report should be similar to and include the same items a general hospital incident report would contain but be expanded to include those incidents that might occur in an MR facility. It should include the actions to take if an incident occurs, what the response should be and the documentation required. There is a good policy published on the ICANL website for adverse reactions and this format could be used for a general incident report: www.icanl.org/icanl/apply/sampledocs.htm
Q. We have submitted our application. Once it is approved, what do we need to do when scheduling patients and getting insurance pre-certification? Will insurance companies ask us for our accreditation prior to letting us do the CT scan?
That answer will vary depending upon the individual insurance companies’ policies. The ICACTL, as well as each of the IAC divisions, does provide verification of laboratories’ accreditation status to insurance companies upon request and many insurers use the listings of accredited laboratories published on the websites as a reference for verification. We also have data sharing set up with some of the private insurers to apprise them of laboratories’ accreditation status.
Q. Do the national LCDs supercede the local LCDs?
Local coverage determinations (LCDs) are local and vary by state or MAC (Medicare Administrative Contractor). To our knowledge there are no national LCD policies.
Q. Do all reading physicians need to be certified in nuclear medicine? We have a board certified cardiologist who was denied payment by Oxford because he is not board certified in nuclear medicine. We are an ICANL accredited lab.
There are some private insurers that in addition to having an accreditation requirement also have additional requirements for physicians, technologists and/or sonographers. It is our understanding that Oxford does require all interpreting physicians to be CBNC certified in addition to being ICANL or ACR accredited. ICANL accreditation has multiple pathways for documentation of experience and training and CBNC is one of those but not required.
Q. What is the physician certification required by the TUFTS policy?
Below is the information we are aware of, as published by TUFTS:
Effective July 1, 2008, all physicians who perform echocardiography services within an office setting will be required to meet one of the following criteria:
For a physician to be privileged for technical and professional echocardiography services (global billing), the physician must be practicing in a practice/facility accredited by the Intersocietal Commission for the Accreditation of Echocardiography Laboratories (ICAEL). If the physician is not ICAEL accredited, then he/she must meet the following criteria:
- The physician must be certified by the National Board of Echocardiography (NBE).
- Ultrasound equipment must meet ICAEL standards.
- Staff sonographers must be licensed in ultrasound.
For a physician to be privileged for professional only echocardiography services the physician must meet one of the following criteria:
- The physician must be certified by the NBE
- The physician must meet Level II training in transthoracic echocardiography interpretation as defined by the American College of Cardiology (ACC)
- Physicians trained before Level II training requirements became standard must meet equivalent requirements established in the ACC/AHA Clinical Competency Statement on Echocardiography.
Q. Do you have any updates on how payors like UnitedHealthcare are going to verify accreditation for reimbursement decisions?
That answer will vary depending upon the individual insurance companies’ policies. Each of the IAC divisions provides verification of laboratories’ accreditation status to insurance companies upon request and many insurers use the listings of accredited laboratories published on the websites as a reference for verification. We also have data sharing set up with some of the private insurers to apprise them of laboratories’ accreditation status.
Q. I currently hold RDCS, RDMS in an outpatient lab and we are not currently accredited yet. I also perform vascular ultrasound and our lab is in Tennessee. I have 10 years of experience in Vascular - will I have to get RVT or RVS to be able to get ICAVL accreditation?
If you are the Technical Director of the vascular laboratory, the ICAVL Standards require that you must have an appropriate credential in vascular testing. Appropriate credentials include: Registered Vascular Technologist (RVT); Registered Vascular Specialist (RVS); Registered Technologist Vascular Sonography [RT(VS)]; if applying
for visceral vascular only Registered Diagnostic Medical Sonographer in Abdomen [RDMS (AB)]; for physician Technical Directors performing only Extracranial and/or Intracranial testing, the American Society of Neuroimaging’s certificate in Neurosonology.
While the additional technical staff members are strongly encouraged to hold an appropriate credential, they have other options for demonstrating that they hold an appropriate level of training and experience.
Q. We are a multi site private physician practice with office-based Nuclear, Echo and Vascular laboratories. Does each site need to apply separately for accreditation? Does each site require its own individual technical and medical directors to comply with accreditation? We see Medicare and private insurance patients.
Yes, your office will be required to seek nuclear accreditation through the ICANL for your nuclear medicine studies, echocardiography accreditation through the ICAEL for your echocardiography studies and vascular accreditation through the ICAVL for your noninvasive vascular studies. The IAC is in the final stages of developing the Online Accreditation application for each division and this will be a great advantage to your practice as shared information such as demographics and staff will only be entered one time. All IAC divisions have specific criteria that must be met in order to apply as a multiple site and if you meet these criteria you may be able to submit one application for each modality and a multiple site addendum. For specifics please visit each of the IAC websites for which you will apply and under the “How To Apply” tab you will see a link to the multiple site requirements. This is a link to the ICAEL policy: www.icael.org/icael/accreditation/multiplesite.htm. As for your question about Medical and Technical directors, yes, each laboratory must designate individuals for these roles within the operation that meet the requirements of each modality for which you will apply.
NEXT PAGE>>
