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Setting the Standard: XR-29 and the Importance of CT Dose Optimization

July 24, 2014
David Fisher,
VP health policy and strategy
at Siemens Healthcare
By David Fisher

This is the third installment of a regular series on policy topics from Siemens Healthcare.

Signed into law April 1, the Protecting Access to Medicare Act did more than prevent a 24 percent cut to physician payments. It also modified Medicare payment for computed tomography (CT) procedures based on the CT scanner's compliance with a new radiation dose optimization standard recently established by the National Electrical Manufacturers Association (NEMA).



Medicare's dose differential payment policy, XR-29 — also known as the Smart Dose standard — is a groundbreaking standard created by the medical device manufacturing community to enhance patient safety.

Effective Jan. 1, 2016, the Medicare payment systems for hospital outpatient procedures, physician offices, and freestanding imaging centers will be modified so that those that do not meet the Smart Dose Standard will be subjected to a 5 percent reimbursement cut for CT scans on noncompliant equipment. Beginning in 2017, that reimbursement reduction climbs to 15 percent.

The Smart Dose Standard is the next step in a long-standing effort by the medical device industry to reduce and optimize dose with an eye toward greater patient safety. Through the Medical Imaging & Technology Alliance (MITA) — the medical device industry's association and a division of NEMA — device manufacturers have worked for years to create policies that optimize patient dose as well as increase its transparency.

These longstanding efforts first gained widespread attention in 2010, when MITA responded to rising concerns regarding patient radiation dose by introducing the Dose Check Standard. Possessing patient dose notification and dose alert features, Dose Check informed CT system users when the dose associated with a CT scan exceeded certain levels.

Those dose notification and alert features found in the Dose Check standard are now part of the new Smart Dose Standard, which also includes automatic exposure control (modulating patient dose in real time), pediatric reference protocols, and DICOM dose-structured reporting. This last feature gives facilities the ability to monitor their institution's dose levels so that they can more easily record and report dose information.

It also eases the establishment of dose reference values, allowing facilities to understand their own dose levels and compare them to other health care facilities.

During the development of the Smart Dose Standard, MITA sought input from key stakeholders, including physicians, radiologic technologists, and physicists. The features included in the standard are well established in the U.S. healthcare system; the vast majority of the current installed base of CT systems is already compliant.

The Smart Dose Standard identifies to health care providers the small portion of the market's CT systems that fail to include these important dose optimization features.

An institution can then assess how a compliant CT system can improve its clinical documentation, which ultimately impacts quality of care; how such a system can boost operational efficiencies in a radiology department (via automatic documentation of radiation exposure in the patient's medical record); and how it can help secure the institution's financial well-being by positioning a facility to maximize reimbursement and avoid reductions beginning in 2016.

With the passage of legislation encouraging implementation of the Smart Dose Standard, our health care system is enabling providers to reduce and optimize dose as well as make it more transparent.

David Fisher is vice president of health care policy and strategy at Siemens Healthcare.

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