MITA Urges Congress to Expand Appropriateness Criteria and Safeguard Patient Access to Diagnostic Imaging


GAO report excludes key data

Washington, D.C. – The Medical Imaging & Technology Alliance (MITA) today said that GAO findings released today regarding self-referral of CT and MRI imaging services excludes key data, noting that the report fails to acknowledge what MedPAC has twice confirmed: that per capita imaging utilization has declined.

Underscoring the report’s flawed analysis, the Department of Health and Human Services (HHS) rejected two of GAO’s three recommendations as unworkable and unnecessary.  HHS agreed to GAO’s recommendation to ‘determine and implement an approach to ensure the appropriateness’ of CT and MRI imaging. MITA urges Congress to adopt physician-developed appropriateness criteria as a way to address this recommendation.

“Qualified physicians regardless of their specialties should be able to provide appropriate imaging services to their patients.  Efforts to limit physicians would threaten patient access to health care providers and technologies while obstructing coordinated care models that have been proven to lower costs and improve care,” said Gail Rodriguez, Executive Director of MITA. “As an alternative to picking winners and losers among providers, policymakers should incentivize the use of physician-developed appropriateness criteria to inform decisions between patients and their doctors.”

“In addition, the GAO report fails to recognize that per capita medical imaging utilization for Medicare beneficiaries has been steadily declining,” said Rodriguez. “In reality, patients are receiving fewer imaging procedures for the second year in a row.”

According to a recent analysis by MITA, medical imaging utilization per Medicare beneficiary declined by 5.1 percent since 2009 and spending on imaging services for each Medicare beneficiary has dropped 16.7 percent since 2006. This downward trend in imaging utilization and spending has been twice confirmed by the Medicare Payment Advisory Commission (MedPAC), which noted in its March 2012 Report to Congress that imaging represents the slowest growing category in the fee-for-service Medicare program.  Yet, despite this downward trajectory, Congress and the Administration have levied reimbursement cuts to medical imaging eight times in the past six years, imposing even greater barriers to patients receiving the right scan at the right time.

In 2011, the Centers for Medicare & Medicaid Services (CMS) selected five physician practices to participate in a two-year Medicare Imaging Demonstration project to test the use of appropriateness criteria. Authorized by the Medicare Improvements for Patients and Providers Act of 2008, the demonstration aims to assess the impact that decision support systems have on the appropriateness and utilization of MRI, CT and nuclear medicine in the beneficiary population.

MITA advocates for the use of physician-developed appropriateness criteria to guide treatment decisions and training of hospital and imaging facility personnel who perform medical imaging exams to ensure the safe and effective use in every venue. In order to provide optimal care and prevent medical errors, physicians and technologists must account for the patient’s individual needs, including adjusting dose levels based on these needs and characteristics.

“The medical imaging industry’s number one priority has always been high-quality patient care,” said Rodriguez. “Whether in private practice or hospital emergency rooms, ensuring operators are appropriately trained to use medical imaging is critical to delivering safe and effective care. Congress should be eliminating barriers to care not creating them.”

Several recent studies have confirmed the benefits of empowering physicians to reduce inappropriate imaging through the use of appropriateness criteria. For instance, in September, researchers highlighted ways in which incorporating SPECT appropriate use criteria in electronic medical records (EMRs) aided primary care physicians in ordering the right test for their patients.  Marlow Hernandez, DO, one of the lead researchers, confirmed that in addition to improving guideline compliance and care delivery, the incorporation is “very simple and inexpensive to implement.”


The Medical Imaging & Technology Alliance (MITA), a division of the NEMA, is the collective voice of medical imaging equipment, radiation therapy and radiopharmaceutical manufacturers, innovators and product developers. It represents companies whose sales comprise more than 90 percent of the global market for medical imaging technology. For more information,