Comments call for removal of unsubstantiated claims on physician self-referral
The American Urological Association (AUA) has provided comments on a new guidance document from the Environmental Protection Agency (EPA), calling for the group to review and remove a section on self-referral. The document, Federal Guidance Report No. 14, “Radiation Protection Guidance for Diagnostic and Interventional X-Ray Procedures,” was released in April for public comment. This document was the EPA’s first update on the medical use of radiation protection programs since October 1976. The recommendations contained in the report represent consensus judgment of an interagency Medical Work Group for the practice of diagnostic and interventional imaging by federal agencies.
Though we realize the guidance report is primarily intended for the federal medical community, the EPA also noted in the draft that the recommendations are also “suitable for use by the broader medical community.” With this understanding, the AUA reviewed the guidance report for relevance to its members and offered comments.
While in general, many of the recommendations represent common practice standards in today’s medical community and are likely used by AUA members who provide imaging services. However, the AUA did call attention to a few recommendations which appear too onerous for independent providers.
Of specific concern for the AUA in the guidance report was the section on physician self-referral. The report acknowledged that the topic is not particularly applicable in federal facilities; thus the comments are targeting civilian facilities. The statements, which the AUA recommended be removed from the report, largely echo protests the AUA has refuted for many years, including:
Providers, other than radiologists, are not properly trained to offer imaging services.
Self-referral leads to overutilization.
Providers self-refer in order to recoup the expense of owning and maintaining the equipment.
The AUA also called attention to its own initiatives regarding imaging services.
In order to provide additional training opportunities to its members, the AUA has worked with the American Institute of Ultrasound in Medicine (AIUM) to develop a practice guideline for the performance of an ultrasound examination in urology.
Urology is concerned about patient-related radiation safety and has advanced the use of lower energy forms of standard radiology tests such at CT scans. Additionally, all of the AUA’s guidelines address imaging where relevant, and the AUA extended this to develop specific imaging guidance (Evidence Report for Imaging in the Management of Ureteral Calculous Disease) to accompany a technical assessment (Clinical Effectiveness Protocols for Imaging in the Management of Ureteral Calculous Disease: AUA Technology Assessment).
The AUA completed an analysisof Medicare’s 100 Percent Physician Supplier Summary Procedure Master File from 2003-2009 to see if urology was increasing imaging utilizations. However, the data clearly noted this was not the case.
The AUA has a long history of challenging legislation and regulation that negatively impacts a urologist’s ability to provide quality patient care. For more information on the AUA’s imaging efforts, visit the AUA website.