ACR sees burden and little benefit from CMS’s plan to tackle ‘excessive radiation dose’
The American College of Radiology says it sees increased burden on clinicians and little benefit from a proposed plan to decrease excessive radiation exposure in hospital settings.
The Centers for Medicare & Medicaid Services is proposing to add a new measure under the Hospital Outpatient Quality Reporting program that relates to radiology. “Excessive Radiation Dose or Inadequate Image Quality for Diagnostic Computed Tomography in Adults” would launch with the voluntary 2025 calendar year reporting period.
ACR said it supports efforts to create radiology-focused patient safety measures. But it is urging “strongly” against mandatory reporting for the measure beginning in 2026, calling it an “extremely premature requirement.”
“This measure necessitates considerable organizational efforts to access and process the data elements required to calculate the measure score,” ACR chief executive William T. Thorwarth Jr., MD, wrote in comments submitted to CMS on Sept. 11. “The complexity of the measure, particularly concerning methods for calculated data elements, requires the creation of measure software and logic by hospital staff or the use of a commercial product.”
Thorwarth noted that there currently is only one software available for this task, created and maintained by vendor Alara Imaging Inc. The steward of this quality measure has indicated that organizations can obtain access to the tool for free. However, integrating this software into existing technology such as electronic health records or PACS would cost radiology providers additional resources and time, he noted.
ACR highlighted concerns around how the new measure would impact rural hospitals and those treating underserved communities. “Given their already-limited resources, implementing this measure in these care settings may prove insurmountable for many,” Thorwarth wrote. The college also has concerns that there is no demonstrated validity or reliability supporting the measure, among other issues.
“The ACR fully supports valid and feasible tools to optimize patient exposure to radiation dose,” Thorwarth wrote. “However, we strongly recommend that CMS take a considered approach to implementing the ‘Excessive Radiation Dose’ measure into the [Hospital Outpatient Quality Reporting] program, allowing a period for larger-scale testing, implementation, and experience with the measure before including it for the CY 2024 reporting period, merely months away. The ACR also urgently requests that CMS rename the measure to remove the misinforming phrase ‘excessive radiation dose’ and use less alarmist language such as ‘optimized dose.’”
You can read ACR’s full comment letter to CMS here. The college also previously raised concerns about the quality measure when the agency initially released the proposed rule in June.
Marty Stempniak has covered healthcare since 2012, with his byline appearing in the American Hospital Association's member magazine, Modern Healthcare and McKnight's. Prior to that, he wrote about village government and local business for his hometown newspaper in Oak Park, Illinois. He won a Peter Lisagor and Gold EXCEL awards in 2017 for his coverage of the opioid epidemic.