MIPPA requires CMS to oversee the accrediting organizations and  authorizes CMS to modify the list of selected accrediting organizations, if  necessary. Federal regulations specify that CMS may conduct “validation  audits” of accredited ADI suppliers and provide for the withdrawal of CMS  approval of an accrediting organization at any time if CMS determines  that the organization no longer adequately ensures that ADI suppliers  meet or exceed Medicare requirements. According to CMS officials, five full-time staff are budgeted to oversee  and develop standards for the ADI accreditation requirement.report was issued in May 2013, CMS has begun to gather input from  stakeholders on the development of national standards for the  accreditation of ADI suppliers, which it intends to develop by the end of  2014. CMS implemented additional changes to Medicare payment policy to help  ensure appropriate payment for ADI services, which had the effect of  reducing Medicare payment for certain imaging services. Effect of Accreditation Requirement on Access to Advanced Diagnostic Imaging in Office Settings Is Unclear in Context of Other Policy Changes

We found that the number of ADI services provided to Medicare  beneficiaries in the office setting—an indicator of access to those  services—began declining before and continued declining after the  accreditation requirement went into effect on January 1, 2012 (see fig. In particular, the rate of decline from 2009 to 2010 was similar to the rate  from 2011 to 2012 for the CT; MRI; and NM, including PET, services in  our analysis. These results suggest that the overall decline was driven, at  least in part, by factors other than accreditation. The percentage decline in the number of ADI services provided in the  office setting was generally similar in both urban and rural areas during  the period we studied, although we found that substantially more services  were provided in urban areas than in rural areas (see fig. The effect of accreditation on access—as illustrated by our analysis of the  trends in ADI services in the office setting—is unclear in the context of  recent policy and payment changes as well as other factors affecting the  use of imaging services. In addition, CMS implemented a  25 percent payment reduction for the professional component of  certain CT and MRI services under the MPPR, effective January 1,  2012—the same date the accreditation requirement went into effect. These policies may have had a spillover effect on Medicare, thus contributing to the decline in ADI services provided to  Medicare beneficiaries from 2009 to 2012. Agency Comments

We provided a draft of this report for review to the Department of Health  and Human Services, and the agency stated that it had no comments.
Why GAO Did This Study

The Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) required that beginning January 1, 2012, suppliers that produce the images for Medicare-covered ADI services in office settings, such as physician offices, be accredited by an organization approved by CMS. MIPPA mandated that GAO issue two reports on the effect of the accreditation requirement. The first report, issued in 2013, assessed CMS's standards for the accreditation of ADI suppliers and its oversight of the accreditation requirement.
In this report, GAO examined the effect the accreditation requirement may have had on beneficiary access to ADI services provided in the office setting. To do this, GAO examined trends in the use of the three ADI modalities—CT; MRI; and NM, including PET—provided to Medicare beneficiaries from 2009 through 2012 that were subject to the ADI accreditation requirement. GAO also interviewed CMS officials, representatives of the Intersocietal Accreditation Commission and the American College of Radiology—the two CMS-approved accrediting organizations that accounted for about 99 percent of all accredited suppliers as of January 2013; and 19 accredited ADI suppliers that reflected a range of geographic areas, imaging services provided, and accrediting organizations used. In addition, GAO reviewed relevant literature to understand the context of any observed changes in ADI services throughout the period studied.

What GAO Found

GAO found that the number of advanced diagnostic imaging (ADI) services provided to Medicare beneficiaries in the office setting—an indicator of access to those services—began declining before and continued declining after the accreditation requirement went into effect on January 1, 2012. In particular, the rate of decline from 2009 to 2010 was similar to the rate from 2011 to 2012 for magnetic resonance imaging (MRI); computed tomography (CT); and nuclear medicine (NM), including positron emission tomography (PET) services. These results suggest that the overall decline was driven, at least in part, by factors other than accreditation. The percentage decline in the number of ADI services provided in the office setting was generally similar in both urban and rural areas during the period GAO studied.
The effect of accreditation on access is unclear in the context of recent policy and payment changes implemented by Medicare and private payers. For example, the Centers for Medicare & Medicaid Services (CMS) reduced Medicare payment for certain CT and MRI services, which could have contributed to the decline in the number of these services. Officials from CMS, representatives from the accrediting organizations, and accredited ADI suppliers GAO interviewed suggested that any effect of the accreditation requirement on access was likely limited.
The Department of Health and Human Services stated that it had no comments on a draft of this report.