Update on Medicare Requirements for Staff Performing Bone Densitometry

Many questions have been raised over the past several weeks about the training and qualifications of personnel performing bone densitometry after several facilities received letters of denial upon submission of Medicare Enrollment application CMS-855B. The denial letters had the following language: “77080 in order to bill for the code above, you must add a technician in Attachment 2D Credentialed by ARRT: R.T. ,BD or ISCD: CBDT. Please make sure to attach a true copy of the technician’s certification. If you cannot provide the information, please remove the code from Attachment 2B” Our phones here in the office were busy with unanswered questions, but we pledged to seek answers that could be shared.

The firestorm of questions did not have readily available answers and the regulation was not easily found. After much research and conferencing with the ISCD, the regulation exists in rules specifically for Independent Diagnostic Testing Facilities (IDTF). It is found in the Performance Standards for IDTFs.  This rule does not apply to hospital outpatient departments or to physician offices where only one test is performed.  Requirements for IDTF only apply to Medicare approvals for imaging exams. The requirements in place are found in Local Coverage Determination 35448 (referred to as the LCD). The LCD lists the required credentials for each imaging code for each procedure.  The beginning of the article lists all of the states that are covered by the requirements for IDTFs. https://www.cms.gov/medicare-coverage-database/details/article-details.aspx?articleId=53252&ver=47&Cntrctr=319&ContrVer=1&CntrctrSelected=319*1&name=Novitas+Solutions%2c+Inc.+(12102%2c+A+and+B+MAC%2c+J+-+L)&s=11&DocType=Active&bc=AgAAAAIAAAAAAA%3d%3d&

The LCD also sets forth requirements for states that have no licensing board to establish credentials and specifies an appropriate national credentialing body may be acceptable.  If there is no state license or certification of the technician performing the test, and no generally accepted national credentialing body exists, education/credentialing and/or experience of the person performing the test must be submitted with the application.

The LCD continues to describe the rules of supervision of diagnostic testing by non-physician practitioners. “Non-physician practitioners may not supervise diagnostic testing performed by others.
Audiologists, psychologists and physical therapists, may personally perform certain diagnostic tests without physician supervision and bill using their own provider number.
Physician supervision of any type is not required for diagnostic tests performed by nurse practitioners or clinical nurse specialists when they are authorized by the State to perform such tests and the testing is within the scope of their practice. (They must bill under their own number.)
Physician assistants require general physician supervision for the performance of diagnostic tests permitted within the scope of their practice authorized by their state.
The supervising physician and non-physician personnel credentialing requirements are listed in Local Coverage Article, A53252, IDTF.”

There are multiple states where legislation is pending in 2017 asking for other health professions to have the authority to supervise and/or perform imaging exams. (ASRT map)

This question will have other implications as time moves forward. The following map shows the states where legislation is pending, enacted, or where it failed.

The outcome of these legislative initiatives could have a severe impact on the delivery of radiologic procedures in multiple environments.

There have been continuous layers of credentialing requirements added for performance of high tech imaging procedures.  It comes as no surprise that certification will be required for all imaging modalities for procedure reimbursement in the future. Purchasers of health care are quick to specify that they want quality health care performed by knowledgeable staff. The quickest path to demonstrate competence, education and training is to sit for an exam and be successful.

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