Question: I plan to purchase Computed Tomographic (CT) scanners and start providing scanning services.  I already offer x-ray services. Are there certain equipment requirements that I should be aware of?

Answer: CMS requires that health care providers who provide CT scanning services comply with the National Electrical Manufacturers Association (NEMA) XR-29 Standard in order to avoid reimbursement penalties. The NEMA XR-29 Standard specifies four attributes of CT scanners that will help optimize and/or manage doses of ionizing radiation and deliver the diagnostic image quality needed by the provider. They are:

  • Digital Imaging and Communications in Medicine (DICOM)-compliant radiation dose structured reporting
  • Dose check features
  • Automatic exposure control
  • Reference adult and pediatric protocols

Further, CMS will reduce the payment for the technical component (and the technical component of the global fee) of the Physician Fee Schedule service by 5 percent in 2016 and 15 percent in 2017 and subsequent years for CT services billed in imaging centers, physician offices, and hospital outpatient settings.  Those services are identified by Current Procedural Terminology (CPT) codes:

  • 70450-70498;
  • 71250- 71275;
  • 72125-72133;
  • 72191-72194;
  • 73200-73206;
  • 73700-73706;
  • 74150-74178;
  • 74261-74263;
  • 75571-75574;
  • Any succeeding codes.

If services are performed on non-NEMA Standard XR-29-2013 compliant CT scans, billers must append modifier –CT, “Computed tomography services furnished using equipment that does not meet each of the attributes of the National Electrical Manufacturers Association (NEMA) XR-29-2013 standard”  to the CPT code. More information on the modifier and the claim adjustment codes can be found in the MLN Matters newsletter at

To determine if your CT equipment complies with the XR-29 Standard, you can contact your CT scanner’s manufacturer. In addition, you should also visit your manufacturer’s XR-29 Vendor Certification Web Portal on the MITA Smart Dose website ( to download verification of compliance.

To further incentivize imaging providers to adopt more advanced x-ray technology, CMS is planning to reduce reimbursement for the technical component (and the technical component of the global fee) for claims submitted for x-rays performed on analog equipment beginning in 2017. The cuts will continue in future years for those also still using computed radiography equipment (figure 1):

X-ray TechnologyYear ImplementedReimbursement Reduction
Computed Radiography20187%
Computed Radiography202310%
Digital RadiographyNoneNone


While CMS has not made it clear how services performed using older technology will be identified, it is expected that they will create a modifier to append to the appropriate CPT code, similar to the XR-29 regulation for CT Scans in 2016. The x-ray CPT codes affected are:

  • 70030-70160;
  • 70190-70330;
  • 70360-70370;
  • 70380;
  • 71010-71130;
  • 72020-72120;
  • 72170-72190;
  • 72200-72220;
  • 73000-73140;
  • 73501-73660;
  • 74000-74022;
  • 74210-74220;
  • 74240-74251;
  • 74270-74280;
  • 74770;
  • Any succeeding codes.

Each method offers its own attributes (figure 2). With that in mind, you will also want to consider the number of x-rays performed in your facility(ies), the staffing and space you have available, as well as the upfront cost when deciding whether to purchase different x-ray equipment.

Analog X-rayComputed Radiography X-rayDirect Digital X-ray
Ordinary X-ray machines use high doseLower dose than analog and higher than digitalNew flat panel detectors allow low dose
Need to repeat X-ray due to low quality of imagesImage transferred to plate, from plate, to the readerConstant quality as Automatic Exposure Control s/w eliminates need to repeat X-ray
Only one local hard copyImage can be digitizedEasy availability also in the Cloud for quality control and research
Poor image or viewer qualitySimilar to quality of DR at high dose levels and can degrade in th time it takes to process the cassetteBetter image quality with respect to contrast and detail detectability
Delay between x-ray exposure and image availabilityImage rendered digitally in under a minuteImage immediately available
Image archiving labor intensiveDigitized image storage is more space efficient than filmEasy storage and instant access to archived images


It is assumed that most organizations have already replaced analog equipment, possibly with computed radiography (CR) before digital radiography (DR) was widely available. If you have not done so yet, it might be worth it to invest in digital radiography since it is inevitable that is the direction the industry is heading.