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Dealing with XR-29 non-compliance

“Its 4th and long for many still dealing with XR-29 non-compliance”

Greetings my ICE colleagues and friends – this month’s blog’s topic is one that many of you may have already dealt with and conquered though some are facing the 4 th quarter clock “two-minute warning” to another patient imaged billing reimbursement reduction effective January 1, 2017!

The Protecting Access to Medicare Act (PAMA) signed into law in April 2014 was the last “patch” of the SGR and included many implications for imaging providers. Among these are requirements that health provider 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. During the summer of 2015, the Centers for Medicare and Medicaid Services (CMS) issued Medicare Physician Fee Schedule (MPFS) and the Hospital Outpatient Prospective Payment System (HOPPS) proposed rules for public comment outlining how the law would be implemented. The final rule was published in late October 2015.

So to review what all of this “XR-29 hullabaloo”, I have bulleted some ofthe highlights below;

  • What are to four attributes that must met? – Answer, DICOM compliant radiation dose structured reporting, Dose check features, Automatic Exposure Control and Reference Adult and Pediatric protocols.
  • What is the law that calls for compliance with XR-29? – Answer, Protecting Access to Medicare Act (PAMA) of 2014
  • What is CMS requiring regarding XR-29 compliancy? Answer, “Beginning January 1, 2016, hospitals and suppliers will be required to report the modifier “CT” on claims for CT scans and the their CPT code. The use of this modifier will result in the applicable payment reduction for the CT service.
  • What are the penalties for non-compliance with XR-29? Answer, the reduction billing reimbursement penalty in 2016 is 5% and hikes up to 15% beginning January 1, 2017.
  • What procedures does this law apply too? Answer, at this time only Medicare Part B patient billing CT procedures that include head/brain, abdomen, pelvis, upper/lower body extremity.
  • What if your CT Scanner is not compliant and you do not report the “modifier” coding? Answer, Medicare will pay the full allowed amount for billing reimbursement. Once Medicare identifies an overpayment has been made, the overpayment amount becomes a debt to the Federal government. Civil monetary penalties may apply if it was a known an overpayment was received and it was not properly reported or returned.

The “end game” here is that its estimated approximately 1500-2500 diagnostic CT scanners are in active use that are not XR-29 compliant. Replacement capital funding at clinical owner facilities has been constrained or possibly non-existent to address this federal mandated law issue. Upgrades from the original equipment manufacturers (OEM) and other solutions may be available though they also carry a cost and are dependent on availability. Challenges and opportunities abound – how are you dealing with the NEMA XR-29 compliancy requirement?


Alan has been in the Clinical Engineering industry for 29+ years having served directly in the academic, governmental and community hospital settings. Alan’s career has spanned from imaging/ biomedical engineer to Director of Clinical Engineering. Alan currently serves today at the Vice President and Senior Advisor level with a leading medical equipment consultative and asset management firm.



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