As members of the Patient, Consumer, and Public Health Coalition, we are writing to strongly urge CMS to maintain the Excessive Radiation Dose or Inadequate Image Quality for Diagnostic Computed Tomography (CT) measure as a mandatory reporting requirement in the Hospital Outpatient Quality Reporting (OQR) Program. The proposed change to make this voluntary makes no sense for an Administration focused on MAHA values of preventing disease and improving the health of all Americans.
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 has harmed too many patients and a voluntary reporting requirement would inevitably harm more patients in the future. CT imaging is an important tool for patients and healthcare professionals, but if the CT quality reporting becomes voluntary, there will be 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 strongly urge you to continue to require this CT quality measure reporting 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 saves lives and this requirement should continue to be an essential part of the OQR Program. Voluntary reporting would harm patients and ultimately increase healthcare costs.
Sincerely,
Cancer Prevention and Treatment Fund of the National Center for Health Research
Breast Implant Safety Alliance
DES Action
Generation Patient
Jacobs Institute of Women’s Health
MedShadow
MRSA Survivors Network
Our Bodies Ourselves
Patient Safety Action Network
SCAD Alliance
TMJ Association
USA Patient Network
Woodymatters