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Prepare For the New X-Ray Differential Payment Policy


How radiology departments can prepare for new legislation regarding X-ray technology.

Recently, Congress acted to upgrade clinical effectiveness and patient safety by enacting its second policy designed to support modern technology in installed imaging systems in the U.S. In December, Congress passed The Consolidated Appropriations Act of 2016, which includes a new public health policy designed to push providers to adopt digital X-ray technology – in short, to convert from film- and cassette-based (CR) radiography systems to fully digital units.

Beginning in January 2017, CMS will impose a 20% reimbursement penalty to the Medicare technical component for X-ray procedures performed on film-based systems. As of January 2018, users of CR-based units will likewise feel the reimbursement pinch, as CMS imposes a 7% penalty to the Medicare technical component of X-ray procedures performed using CR systems. That reduction escalates to 10% in January 2023.

A sizable chunk of the X-ray community could feel the effect of these reimbursement cuts. While only about 1% of providers currently use film, approximately 59% still utilize CR systems, with the remaining 40% operating DR units.¹

This new differential payment for X-ray is similar to a 2014 policy implemented by Congress for CT procedures. That policy, which took effect earlier this year and which is based on the XR-29 standard for dose optimization, lowers reimbursement for providers with CT scanners that fail to comply with the new standard. An argument for the rationale for both policies: Adoption of current medical imaging technology is in the patient’s best interest. And from a practical standpoint, the use of digital X-ray systems is in line with the increasing trend toward digitalization of the EHR in the U.S.[[{"type":"media","view_mode":"media_crop","fid":"46554","attributes":{"alt":"Matthew Koch","class":"media-image media-image-right","id":"media_crop_9306584424044","media_crop_h":"0","media_crop_image_style":"-1","media_crop_instance":"5415","media_crop_rotate":"0","media_crop_scale_h":"0","media_crop_scale_w":"0","media_crop_w":"0","media_crop_x":"0","media_crop_y":"0","style":"height: 169px; width: 140px; border-width: 0px; border-style: solid; margin: 1px; float: right;","title":"Matthew Koch, Director of Policy and Strategy, Government Affairs and Policy Department, Siemens Healthcare","typeof":"foaf:Image"}}]]

Medicare has not yet published rules to implement the differential X-ray payment. Initial proposals will become public this summer, with the final version published in the fall. To avoid reimbursement reductions, providers who use analog X-ray equipment should begin planning their transition to digital now. The following three steps can help ensure that they aren’t hit with a payment penalty:

Inventory your assets for X-ray exams that are billed under fee-for-service (FFS) Medicare and identify your analog equipment.

Assess the volume of X-ray procedures performed on noncompliant equipment to calculate the financial impact to your institution. 

Develop and execute an asset plan that converts your noncompliant X-ray systems to digital.[[{"type":"media","view_mode":"media_crop","fid":"46555","attributes":{"alt":"David Fisher","class":"media-image media-image-right","id":"media_crop_344834784860","media_crop_h":"0","media_crop_image_style":"-1","media_crop_instance":"5416","media_crop_rotate":"0","media_crop_scale_h":"0","media_crop_scale_w":"0","media_crop_w":"0","media_crop_x":"0","media_crop_y":"0","style":"height: 210px; width: 140px; border-width: 0px; border-style: solid; margin: 1px; float: right;","title":"David Fisher, Head of Global Government Affairs and Policy, Siemens Healthcare","typeof":"foaf:Image"}}]]

While some providers may flinch initially at the reality of CMS-incentivized adoption of digital X-ray technology, consider that the average X-ray system is over 13 years old and likely will require replacement in the not-too-distant future.¹ Ultimately, the short-term cost associated with accelerating a health care facility’s inevitable transition to digital X-ray is in line with its larger mission statement: to provide optimal patient care with current technology.

Looking forward, Congressional consideration of additional differential payment policies is a real possibility. Congress has demonstrated support for this type of policy as a means to improve public health as well as reduce overall federal spending on healthcare. Expect government support to continue for standards that improve clinical effectiveness and patient safety.


1. IMV 2013 X-ray/DR/CR Market Outlook Report.

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