Can Third-Party Software Make Your CT Scanner Compliant with NEMA XR-29?

Starting January 2016, reimbursement for Medicare patients undergoing CT studies in outpatient and stand-alone imaging centers will be based on compliance with the National Electrical Manufacturers Association (NEMA) standard XR-29-2013. Specifically, for any studies performed using CT scanners that don't comply with the four requirements laid out in XR-29-2013, the reimbursement amount will be reduced by 5% in 2016; in 2017 and subsequent years, it will be reduced by 15%. This standard, which addresses CT dose control concerns, is part of the Protecting Access to Medicare Act of 2014, which was passed in April 2014.

All new CT scanners and those purchased new within the last few years meet the XR-29 requirements, or can be upgraded by the manufacturer to meet them. However, some older scanners—perhaps a third of installed systems—are not upgradable by the manufacturer. A number of third-party vendors are offering software upgrades purported to make scanners compliant with XR-29. Hospitals have been asking us whether these upgrades are a suitable approach.

The answer is that third-party software solutions will, at best, help meet only one of the four requirements of XR-29-2013—specifically, the DICOM dose structured reporting requirement. And even for that requirement, third-party...