Imaging Services

The American Academy of Otolaryngology – Head and Neck Surgery recognizes the importance of quality standards and accreditation for medical imaging and knows that Academy members look to the foundation to provide leadership on this issue.  In response to these developments, the Academy has established the Imaging Committee. This committee, chaired by Gavin Setzen, MD, is charged with providing additional resources and training for continuing medical education in this area and with monitoring continuing legislative and reimbursement developments. Below are recent advocacy efforts related to reimbursement and coverage of CT imaging services.

Contact Jenna Kappel with any questions regarding health policy or payment issues related to CT imaging.
Contact Education with any questions regarding medical education related to CT imaging and the accreditation process.

*NEW* Physician Community Urges Congress to Preserve Stark Law Exemption (3/27/2014)
On March 18, the AAO-HNS joined the Coalition on Patient-Centered Imaging in sending a letter to Congress urging preservation of the in-office ancillary services exception (IOASE) to the “Stark” law and rejection of the Administration’s budget proposal to restrict the IOASE. Leaders of the Senate Finance, House Ways & Means, and Energy & Commerce Committees received the letter. Click here to view the letter.

ACR Releases New and Updated Appropriateness Criteria (12/12/2013)
The American College of Radiology has released new and revised Appropriateness Criteria (ACR AC), which are evidence-based guidelines to assist providers in making the most appropriate imaging or treatment decision for a specified medical condition. More than 80 physicians from specialties participate in the development and review of the topics which includes 29 updated, and 12 new, topics from various expert panels. AAO HNSF Imaging Committee and Academy members serve as Expert Panel members of the ACR AC, particularly for Neurologic Imaging Criteria. Academy members, including Brian Nussenbaum, MD, Brad Kesser, MD (specialty reviewer for new updated hearing loss/vertigo diagnostic imaging), and James Hadley, MD (specialty reviewer for Orbits, Vision and Visual Loss, Sinusitis-Child, Headache, and Cerebrovascular Disease) have contributed to the review and update of the ACR AC, particularly for Neurologic Imaging Criteria. The AAO-HNSF Imaging Committee has also given input to revisions on Sinonasal Disease, amongst other clinical condition topics. Click here to access the full library of ACR AC.

National Forum: Exploring the Value of IAC Accreditation (10/24/2013)

The AAO-HNS was one of the original sponsoring organizations of the Intersocietal Accreditation Commission (IAC) and has been involved in developing and maintaining CT imaging accreditation standards since its inception, with Gavin Setzen, MD, the President of the Intersocietal Accreditation Commission CT Division (IAC-CT). On October 29th, the IAC is hosting the first of its kind Forum held in Washington, DC, including representatives from specialties involved in CT imaging, government agencies, including the FDA, CMS, GAO, private payers, as well as public service organizations. CT accreditation is important because it helps to ensure optimal quality and standardization of testing and reporting in CT imaging, and also helps to ensure that the clinician is providing the right test at the right time on the right patient. Also, the Centers for Medicare & Medicaid requires accreditation of facilities that furnish advanced imaging services, including CT, in order to receive reimbursement for services provided to Medicare patients. This Forum is an exciting opportunity for all stakeholders to meet face-to-face to share opinions and recommendations to make accreditation more meaningful. David Nielsen, MD, AAO-HNS CEO and EVP, Richard Waguespack, MD, AAO-HNS President, and Gavin Setzen, MD, AAO-HNS Secretary-Treasurer will attend the meeting to provide comments on a sponsoring organization’s perspective on the strengths and weaknesses of the current accreditation model. Stay tuned for a summary of outcomes of the meeting.

atient Radiation Safety Mandates Gain Traction in the States

Several states, such as California and Texas, have implemented rules or laws which mandate adherence to CT and interventional radiography imaging guidelines for healthcare providers. Awareness of radiation dose safety has increased tremendously, and continues to gain momentum among state legislatures. To view further information about the law passed in Texas, click here. To view California's Information Notice on this legislation from 2010 and its amendment in 2012, click here.

In Connecticut, a bill (Raised Bill No. 2463) similar to California's legislation  on this issue was proposed  but was referred to the Joint Committee on Public Health and did not receive a hearing. If reintroduced for the 2014 legislative session, the bill would:

• Require providers to  record CT radiation dose in patient radiology reports
• Require annual inspection of CT scanners to ensure displayed dose doesn’t deviate more than 20% from actual measured dose
• Mandate five days for reporting to the state and referring physician and 15 days for reporting to patients certain error events (e.g. repeat CT raising cumulative dose to an excessive level, wrong site, permanent damage to patient caused by dose) when dose thresholds, to be established by the Commissioner of Public Health, are exceeded

The Health Policy team will continue to monitor this issue in the coming months.  If similar legislation is introduced in your state, contact the Health Policy team at

Comparative Billing Reports Issued on Advanced Diagnostic Imaging (4/12/12)

On Thursday, February 16, the Centers for Medicare & Medicaid Services (CMS) sent a national provider comparative billing report (CBR) to certain providers addressing their advanced diagnostic imaging use. CBRs, produced by Safeguard Services under contract with CMS, contain actual data-driven tables and graphs with an explanation of findings that compare a provider’s billing and payment patterns to those of their peers located in their state and across the nation. A maximum of 5,000 providers were selected per CBR topic including Advanced Diagnostic Imaging, Sleep Studies, Spinal Orthotics, and other categories.

Definition of Peer
CBRs were distributed by comparing physicians imaging utilization compared to their peers. According to the CBR website, "peer" is defined as any other provider other than radiologists, oncologists, and IDTFs, who has paid claims for advanced diagnostic imaging codes.

Academy Advocacy Efforts
In March, the Academy attended a meeting with CMS staff and at the meeting, the issue of reports came up. Staff talked with the CMS Deputy Director about the Academy's concerns regarding the lack of communication between CMS and societies like the Academy. We also have concerns regarding the definition used in the CBRs for "peer." The CMS Deputy Director expressed interest in talking with us further, so we expect to have more dialogue with CMS staff about this concern, as well as the definition of "peer" and where this effort may be leading.

CMS has indicated that CBRs are not intended to be punitive or sent as an indication of fraud, but are intended as a proactive statement that will help providers identify potential errors in their billing practice. However, the Academy is monitoring the effort as the reports may be part of future rulemaking processes for physician payment policy. If CMS does propose new policies, the Academy will advocate for members and will comment on any proposed policy that may impact Otolaryngology-head and neck surgeons.

In the CBR letters sent to providers, the June 2011 MedPAC report focusing on the billing of diagnostic imaging services and concerns with physician “self referral.” In this report, MedPAC recommended the establishment of a prior authorization program. The Academy urged the Congress to reject this recommendation and more information including the Academy’s letter to Congress can be found below.

What You Can Do if You Receive a Report
The Academy recommends members use the American College of Radiology’s (ACR) Appropriateness Criteria (see information below) to assist referring physicians in making the most appropriate imaging or treatment decisions for specific medical conditions. Information and comments from the Academy on Appropriateness Criteria can be found below. Once the AAO-HNSF’s Clinical consensus statement: CT Imaging Indications for Paranasal Sinus Disease is released in early summer 2012, this will also be a helpful resource for members.

Academy members that received CBRs are encouraged to contact their Carrier to discuss issues with the CBRs and their definition of "peer" at a local level. In the past, discussions with Carriers at a local level have been successful in explaining issues like this and changing the direction of the effort.

SafeGuard Services LLC, the company awarded the Comparative Billing Report (CBR) contract, has developed a website to address Frequently Asked Questions. This site can be found here.

If you have questions about your CBR, you can contact SafeGuard Services LLC at (530) 896-7080 or at If you have questions about your claims, please contact your Medicare Administrative Contractor. If you have received a CBR, please contact the Academy at and send us a copy of the CBR with all sensitive and confidential materials redacted so we can continue to monitor this situation.

Imaging Resources

AAO-HNS Position Statement: Point-of-Care Imaging in Otolaryngology - UPDATED

AAO-HNS Bulletin Articles on Imaging Services CMS Requirements for Advanced Imaging Accreditation

Providers who furnish the technical component (TC)  for advanced imaging services (MRI, PET, CT, and nuclear medicine imaging) must be accredited by January 1, 2012 by the:

• American College of Radiology (ACR)
• Intersocietal Accreditation Commission (IAC)
• The Joint Commission (TJC)

IAC Presentation: History & Useful Tips to Ensure Optimal Outcomes with Accreditation Process to learn more about the accreditation process.

Page last updated: October 24, 2013

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