Comments to Government

Statements to MedPAC on Behalf of the CQU

These public comments on accreditation and/or credentialing requirements for Medicare reimbursement were made by Coalition for Quality Ultrasound (CQU) representatives on October 28, 2004 in Washington, DC during an open general meeting hosted by MedPAC.

Introduction

Julie Muroff, Sidley Austin Brown & Wood

I'm Julie Muroff, here on behalf of the Coalition for Quality in Ultrasound (CQU), which is an alliance of 14 leading diagnostic medical ultrasound societies and organizations that support the adoption of standards requiring the use of accredited facilities and/or credentialed technical component personnel in order to maximize the quality of patient care and to control costs. The CQU greatly values the work of MedPAC and the significance of its role in advising Congress about issues that impact the Medicare program. In particular, the CQU shares MedPAC's concern about the increase in the utilization of imaging services that has occurred in recent years, which was addressed in MedPAC's report to Congress this June and in Ariel Winter's report this morning. We appreciate MedPAC's acknowledgement of laboratory accreditation and technical component personnel credentialing requirements as important means of controlling utilization and ensuring the appropriateness of services. The CQU is committed to implementing these standards as critical quality control measures for all ultrasound services because they are a proven means of controlling inappropriate utilization.

The CQU submitted comments to MedPAC on September 3, demonstrating the need to urge Congress to adopt these accreditation and credentialing requirements more widely within the Medicare program, given their present success in controlling over-utilization. Specifically, our comments elaborated on: (i) The growing consensus of ultrasound-related medical societies and organizations, as well as Medicare carriers, that credentialing/accreditation requirements are essential to ensure that patients receive, and that Medicare pays for, only those studies that meet certain minimum standards of quality assurance; (ii) The threat to the safety of patients, and the substantial unnecessary costs when ultrasound services are provided by uncredentialed technologists or sonographers and unaccredited laboratories; (iii) The Medicare program's frequent use of accreditation or credentialing standards as the principal means of controlling inappropriate utilization and of ensuring the highest quality of care; and (iv) The documented availability of accredited laboratories and credentialed vascular technologists and sonographers.

A few CQU members are here today to provide a brief statement that reflects their expertise on the significance of credentialing and accreditation standards:

ARDMS Statement

Dale Cyr

ARDMS credentials ultrasound professionals, primarily sonographers and vascular technologists in the three major clinical areas of sonography. Cardiac sonography is reflected in the RDCS credential, vascular ultrasound is reflected with the RVT credential and general sonography, which is in the clinical areas of obstetrics, gynecology and abdominal is documented in the RDMS credential. These ARDMS credentials are widely accepted by the medical community. ARDMS has over 45,000 registrants.

Credentials can only be earned through examination. The examinations are psychometrically validated to document the skills, knowledge and education required to perform sonography. As sonography is the most operator dependent imaging modality it is essential that the operator/sonographer assures the patient of basic competency levels of practice for their safety and care. Basic competency in sonography, that is validated allows the physician to obtain appropriate and accurate technical and clinical information for final diagnosis that leads to appropriate treatment algorithms.

For the patient and the ultrasound professional individual the only documented measure of requisite skills, knowledge and attributes to perform sonography is through credentialing.

IAC (ICAVL & ICAEL) Statement

Tammie Sloper

I am Tamara Sloper, representing the Intersocietal Accreditation Commission; the ICAVL: Intersocietal Commission for the Accreditation of Vascular Laboratories and the ICAEL: Intersocietal Commission for the Accreditation of Echocardiography Laboratories.

Accreditation focuses on the facility in which ultrasound is provided. Accreditation provides an ongoing peer review evaluation; looking at every aspect of the operation including training, experience and credentials of the physicians and sonographers, the instrumentation used in the examinations and a variety of pathology, as demonstrated by required case studies.

To date, the ICAVL has accredited 1500 vascular laboratories and the ICAEL 925 echocardiography laboratories. Each of these accreditation programs is widely supported by the various medical specialties using the modalities

SVU Statement

Anne Jones

In 1981, the SVU petitioned the American Registry of Diagnostic Medical Sonographers (ARDMS) to create a specialty exam in noninvasive vascular technology. The first examinations in vascular physics and vascular technology were offered in 1983. Since that time, over 10,000 vascular technologists have acquired the Registered Vascular Technology (RVT) credential. The RVT credential is the standard of excellence within the profession, and has become a requirement for employment and reimbursement in most states.

Credentialing assures patients, employers and the public that the individual performing an ultrasound examination is competent. Certification by a nationally recognized, ultrasound credentialing body documents, at the minimum, that an individual has met educational prerequisites and by passing a series of specialty-specific exams, and is proficient in diagnostic medical sonography/vascular technology. It also assures patients that once the individual is certified, they are compelled to complete continuing medical education courses to maintain their certification. The combination of educational and clinical experience, successful completion of the certification exam and maintenance of continuing medical education is a powerful assurance of competence.

Accreditation provides similar assurances about the facility where ultrasound examinations are performed. The Society for Vascular Ultrasound was a founding member of the Intersocietal Commission for the Accreditation of Vascular Laboratories (ICAVL). Support of the ICAVL's mission demonstrates that SVU believes in standards — not just for the individual performing the ultrasound examination —but the entire facility providing diagnostic vascular services. The accreditation process evaluates the organization, personnel, ultrasound instrumentation, diagnostic criteria, technical protocols and the background, education, experience and credentialing of all medical and technical staff involved in providing ultrasound services. The combination of personnel credentialing and facility accreditation is a powerful assurance of quality and excellence in ultrasound. By evaluating every component of noninvasive vascular testing, the patient is assured that the diagnosis will be accurate, the procedures timely and the instrumentation state of the art.