Coalition comment to CMS on on CT Quality Measures Included in the Proposed Rule for the Hospital Inpatient Quality Reporting (IQR) Program

As members of the Patient, Consumer, and Public Health Coalition, we are writing to enthusiastically support the CT quality measures developed by researchers at the University of California, San Francisco: Excessive Radiation Dose or Inadequate Image Quality for Diagnostic Computed Tomography (CT) in Adults, which is currently included in the proposed rule for the Hospital Inpatient Quality Reporting (IQR) Program.

The Coalition includes nonprofit organizations representing millions of patients, consumers, researchers, and doctors united to ensure that medical treatments are safe and effective.  The coalition does not have paid staff and does not accept funding from any outside sources, so we have no conflicts of interest.

Excess radiation exposure from CT scans poses serious risks to patients.  CT imaging can be tremendously useful to patients, but there is currently no national oversight of radiation dosing, resulting in wide variation in the radiation doses used for CT.  This can be especially dangerous because many patients undergo numerous CT scans.  We support this CT quality measure because it establishes a floor and a ceiling to provide an optimal level of radiation exposure for imaging for numerous different conditions, without reducing the diagnostic benefits of those scans. Standardizing CT scan radiation exposure is long overdue, and for that reason we applaud the inclusion of this measure in the IQR Program. However, we strongly urge the earlier implementation of the measure: 2024 should be the initial year of voluntary reporting, which is one year earlier than proposed. In the long term, we urge CMS to make the measure mandatory for reporting entities. Given the enormous number of exams performed annually and the unacceptable variation in radiation dose, this measure would greatly improve safety if mandatory and enacted without delay.

If you have any questions, please contact Sophia at


AMSA Wisconsin

Medical Device Problems

MRSA Survivors Network

National Center for Health Research

National Women’s Health Network

Our Bodies Ourselves

Patient Safety Action Network

TMJ Association

USA Patient Network


Washington Advocates for Patient Safety


Leave a Comment

Your email address will not be published.