ACR ACCREDITATION : FAQS FOR MEDICAL PHYSICISTS Priscilla F. Butler, MS, Senior Director and Medical Physicist, ACR Quality and Safety

Does your facility need help on applying for accreditation? In each issue of this newsletter, I'll present frequently asked questions (FAQs) of particular importance for medical physicists. You may also check out the ACR's accreditation web site portal for more FAQs, accreditation application information, and QC forms.

The Protecting Access to Medicare Act (PAMA) included requirements that health care providers comply with the National Electrical Manufacturers Association (NEMA) XR-29 Standard Attributes on CT Equipment Related to Dose Optimization and Management, also known as MITA Smart Dose. The Centers for Medicare and Medicaid Services (CMS) is responsible for implementing the law and their regulations went into effect on January 1, 2016. The following questions discuss the ACR's most recent guidance on this topic. See the ACR's NEMA XR-29 (MITA Smart Dose) Standard: Frequently Asked Questions for more information.

Q. What is XR-29?
A. The NEMA XR-29 standard (MITA Smart Dose) specifies four attributes of CT scanners that "contribute to or help perform optimization and or management of doses of ionizing radiation while still enabling the system to deliver the diagnostic image quality needed by the physician." CT scanners meeting the XR-29 Standard have the following:

• DICOM-compliant radiation dose structured reporting. See NEMA XR 29-2013 (Standard Attributes on CT Equipment Related to Dose Optimization and Management) and the DICOM website.
• Dose check features. See NEMA XR 25-2010 (Computed Tomography Dose Check).
• Automatic exposure control. See NEMA XR-28-2013 (Supplemental Requirements for User Information and System Function Related to Dose in CT).
• Reference adult and pediatric protocols. See NEMA XR-28-2013 (Supplemental Requirements for User Information and System Function Related to Dose in CT).

Q. How will noncompliance with XR-29 standards be verified?
A. According to the Medicare Claims Processing Manual, Chapter 12– Physician/Nonphysician Practitioners, (issue 1-6-16) 20.4.7:

"The statutory provision requires that information be provided and attested to by a supplier and a hospital outpatient department that indicates whether an applicable CT service was furnished that was not consistent with the NEMA CT equipment standard...The statutory provision also provides that such information shall be verified, as appropriate, as part of the periodic accreditation of suppliers under SSA section 1834(e) and hospitals under SSA section 1865(a)."

(See CMS Transmittal #3402, section 20.4.7.)

Q. Our facility is accredited in CT with the ACR. How will ACR verify that our CT scanners do or do not comply with the XR-29 standards?
A. The statutory provision for XR-29 provides that "such information shall be verified, as appropriate, as part of the periodic accreditation of suppliers under SSA section 1834(e) andhospitals under SSA section 1865(a)." (See CMS Transmittal #3402, section 20.4.7.) The ACR is currently asking its accredited facilities for a copy of each CT unit's Certificate of NEMA XR-29 Compliance. Going forward, the ACR will request copies of Certificates of NEMA XR-29 Compliance for each unit as part of the routine accreditation application and renewal process. Once CMS provides accrediting organizations with final criteria and procedures to verify and report CT system compliance with XR-29, the ACR will share that information with our accredited facilities.

Q. Are there published requirements for who may prepare certificates of NEMA XR-29 Compliance?
A. No. If you have questions regarding certificate compliance, please contact CMS.

Q. Our CT scanner meets some but not all of the four XR-29 provisions. Must our scanner meet all of the XR-29 provisions in order to obtain full reimbursement?
A. Yes, your scanner must meet all of the following XR-29 provisions in order to obtain full reimbursement.

• DICOM-compliant radiation dose structured reporting.
• Dose check features.
• Automatic exposure control.
• Reference adult and pediatric protocols.

Q. Our CT scanner manufacturer has informed us that they are unable to upgrade our scanner so that it is compliant with XR-29. May we modify our CT scanner with a commercial 3rd party solution to meet XR-29 compliance?
A. Possibly. Please contact CMS to discuss.

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