New CT System Dose Standards – Avoiding Medicare Penalty HR 4302


TRYING TO DO MORE WITH LESS With all the changes in the healthcare system over the past few years, most of the clients we’ve recently worked with have faced with a similar situation – older outdated x-ray equipment, and the inability to upgrade it. Be it because of limited capital, lower reimbursements, or just plain uncertainty over how things will turn out, many hospitals have simply had to continue using older x-ray equipment until it dies or until they are in a position to replace it with a new system, whenever that may be.For those who find themselves in a similar situation with an older CT scanner system that needs replacing, help may be on the way. Recent legislation passed by the Senate (H.R. 4302, the Protecting Access to Medicare Act of 2014) includes reimbursement reductions for CT equipment that does not meet certain radiation dose optimization standards by January of 2016. So, you may not only want to but need to consider upgrading your CT imaging system soon.


In April of 2013 the National Electrical Manufacturers Association’s Medical Imaging and Technology Alliance (more commonly referred to as MITA) published XR29 (XR-29-2013) Standard Attributes on CT Equipment Related to Dose Optimization and Management. According to MITA, the new standard includes four key features of CT equipment that enable optimization or management of radiation dose delivery while also providing high quality medical images:

  • “DICOM (Digital Imaging and Communications in Medicine) Radiation Dose Structured Report, which enables recording of post-exam dose information in a standardized electronic format. This information can be included in the patient record, promoting the establishment of diagnostic reference levels, as well as facility dose management and quality assurance.
  • CT Dose Check, which incorporates two features-dose notifications and dose alerts-that warn operators and physicians when dose exceeds established thresholds.
  • Automatic exposure controls (AEC), which automatically adjust the amount of radiation within prescribed bounds as needed to achieve the desired image quality. Studies of AEC procedures have demonstrated dose reductions when used properly.
  • Pediatric and adult reference protocols, a set of pre-loaded parameters on a CT system that can be selected by the operator to complete a particular clinical task, such as capturing an image of the abdomen.”


While the new standards have been around nearly a year, the recent legislation enforces the new standards and gives you until January of 2016 to comply. According to the Society of Cardiovascular Computed Tomography (SCCT) there would be a “technical component payment reduction of 5% for 2016, and 15% for 2017 and beyond. This would apply to both the physician fee schedule and the hospital outpatient prospective payment system.”It appears that if you have very old CT equipment incapable of being updated to meet these new standards, then your system would need to be replaced. A recent article in the Radiology Business Journal estimates that “one-third of the outpatient installed CT base will need to be replaced if providers wish to avoid the 5% penalty.” That means that an estimated two-thirds of existing systems already meet or can be upgraded to meet the new standards.Reading between the lines, the Medicare penalty is there in part to pay more to providers that have invested in state-of-the-art technology and less to those with aging technology.


It’s important to keep in mind a few things. First, this applies only to outpatient settings at this time – inpatient systems are not affected. Secondly, you have until January 2016 to comply.If you have older CT equipment and you are unsure of whether or not it complies with these new standards, check with your OEM right away. Best-case scenario is that the CT equipment is good to go, but if not, there is a chance that it can be upgraded. If your system is part of the 1/3 in the US that doesn’t meet the standard and can’t be upgraded, then you will want to start laying the groundwork right away for capital approval for a new CT system. If you haven’t been able to get approval to replace your older system by now, the 5% Medicare penalty will hopefully provide the needed incentive.At Modular Devices Inc. we’re certainly concerned, as everyone should be, with x-ray overexposure and limiting dose levels, which is why our fleet of interim modular and Mobile CT Labs all have newer equipment that meets these new standards.If you have questions about H.R. 4302 and how it affects you, or MDI’s fleet of interim Mobile CT Labs, please leave a comment or contact us.

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