[Intl_DxMedPhys] [External] Re: EXT MSG Fwd: The New CMS Measure: Methods for Size-Adjusted Dose and Their Variabilities

Oumano, Michael MOumano at brownhealth.org
Mon Mar 17 11:23:02 EDT 2025


Thank you Olav! This is perfect. I can't tell you how helpful this is.

Cheers!

-Mike

________________________________
From: Olav Christianson <olav.christianson at gmail.com>
Sent: Monday, March 17, 2025 11:05 AM
To: Oumano, Michael <MOumano at brownhealth.org>
Cc: DxMedPhys List <intl_dxmedphys_wd_osu_list at lists.osu.edu>
Subject: Re: [Intl_DxMedPhys] [External] Re: EXT MSG Fwd: The New CMS Measure: Methods for Size-Adjusted Dose and Their Variabilities

Mike,

1. This is the best list I have been able to find for available eCQMs. The list changes each year.

MIPS (Hospitals must report on 6 MIPS quality measures that are self-selected from a list.)

https://urldefense.com/v3/__https://ecqi.healthit.gov/ep-ec?qt-tabs_ep=ec-ecqms&globalyearfilter=2025&global_measure_group=eCQMs__;!!KGKeukY!2QT2bLWkfooa93rKRLkiKLMluUvYdYv5mISg4IQ5Tlxty-TuHY5l39fcmDWfDfvuCTp5IMtASHClxxosfjqjNGs_OHzjMx96_lVixVmdl7Q$ 

IQR (Hospitals must report on 3 eCQMs chosen by CMS and 3 additional eCQMs that are self-selected from a list of remaining eCQMs.)

https://urldefense.com/v3/__https://ecqi.healthit.gov/eh-cah?qt-tabs_eh=eh-cah-ecqms&global_measure_group=3716&globalyearfilter=2025__;!!KGKeukY!2QT2bLWkfooa93rKRLkiKLMluUvYdYv5mISg4IQ5Tlxty-TuHY5l39fcmDWfDfvuCTp5IMtASHClxxosfjqjNGs_OHzjMx96_lViQ9gqGg8$ 


2. Here are links to the federal register document and another source from CMS with the timeline for mandatory reporting for outpatient quality reporting. Search for "excessive radiation" in the documents.

https://urldefense.com/v3/__https://www.federalregister.gov/d/2023-24293/p-221__;!!KGKeukY!2QT2bLWkfooa93rKRLkiKLMluUvYdYv5mISg4IQ5Tlxty-TuHY5l39fcmDWfDfvuCTp5IMtASHClxxosfjqjNGs_OHzjMx96_lVi6HyQ0AI$ 

https://urldefense.com/v3/__https://www.cms.gov/newsroom/fact-sheets/cy-2024-medicare-hospital-outpatient-prospective-payment-system-and-ambulatory-surgical-center-0__;!!KGKeukY!2QT2bLWkfooa93rKRLkiKLMluUvYdYv5mISg4IQ5Tlxty-TuHY5l39fcmDWfDfvuCTp5IMtASHClxxosfjqjNGs_OHzjMx96_lViPoO0_bE$ 

-Olav

On Fri, Mar 14, 2025 at 9:18 AM Oumano, Michael <MOumano at brownhealth.org<mailto:MOumano at brownhealth.org>> wrote:
This is extremely helpful. Thank you Olav.

I do have a couple remaining questions:

  1.
For IQR and MIPS, where can I find the complete list of eCQMs?
  2.
For OQR, is there a primary document from CMS that states the new 2027 mandatory date?

-Mike

________________________________
From: Olav Christianson <olav.christianson at gmail.com<mailto:olav.christianson at gmail.com>>
Sent: Friday, March 14, 2025 8:59 AM
To: Oumano, Michael <MOumano at brownhealth.org<mailto:MOumano at brownhealth.org>>
Cc: Matt Wait <Matt.Wait at kp.org<mailto:Matt.Wait at kp.org>>; DxMedPhys List <intl_dxmedphys_wd_osu_list at lists.osu.edu<mailto:intl_dxmedphys_wd_osu_list at lists.osu.edu>>
Subject: Re: [Intl_DxMedPhys] [External] Re: EXT MSG Fwd: The New CMS Measure: Methods for Size-Adjusted Dose and Their Variabilities

Michael,

The excessive radiation eCQM is part of 3 programs with CMS: Outpatient Quality Reporting (OQR), Inpatient Quality Reporting (IQR), and the Merit-based Incentive Payment Systems (MIPS).

  *   For the IQR and MIPS programs starting this year, it is on the list of self-selected eCQMs. This means that you have to report on a certain number of eCQMS from the list, but you get to choose which ones.
  *   For OQR, it is currently voluntary but will become mandatory in 2027. That means all hospitals paid under the Outpatient Prospective Payment System (OPPS) for outpatient services will need to report on this eCQM by 2027. This includes most hospitals that provide outpatient services. It was initially scheduled to become mandatory in 2026 but was later pushed back until 2027.

I hope that helps.

Best,

Olav

On Thu, Mar 13, 2025 at 12:32 PM Oumano, Michael <MOumano at brownhealth.org<mailto:MOumano at brownhealth.org>> wrote:
Thank you all for this important thread. I apologize in advance if this has already been addressed on the listserv and I'm just missing it, but I know a lot of people (including myself) are still confused on if/when compliance with the CMS measure is actually required. The clearest statement I've seen on this thus far has come from this AAPM statement<https://urldefense.com/v3/__https://www.aapm.org/pubs/enews/documents/CMSNewQualityMeasure_082023.pdf__;!!KGKeukY!2QT2bLWkfooa93rKRLkiKLMluUvYdYv5mISg4IQ5Tlxty-TuHY5l39fcmDWfDfvuCTp5IMtASHClxxosfjqjNGs_OHzjMx96_lVi-5V2Ufw$ >, which says "For physicians, CMS is proposing the new Merit-based Incentive Payment System (MIPS) quality measure beginning with the calendar year (CY) 2024 performance period on January 1, 2024 to determine MIPS payments in 2026. For hospital outpatient departments, the proposed measure begins with a voluntary reporting period beginning in CY 2025 and mandatory reporting beginning with the CY 2026 reporting period for CY 2028 payment determination." But I find even this quite confusing. When is/was the deadline for hospital inpatients?

-Mike


Michael Oumano, PhD, DABR, DABSNM, MRSE, CHP, CMLSO

Radiation Safety Officer, Medical Physicist, Laser Safety Officer

Adjunct Professor of Diagnostic Imaging and Radiation Oncology

office 401-444-2925

fax 401-444-4446

cell 203-598-2683





________________________________
From: Intl_dxmedphys_wd_osu_list <intl_dxmedphys_wd_osu_list-bounces+moumano=lifespan.org at lists.osu.edu<mailto:lifespan.org at lists.osu.edu>> on behalf of Olav Christianson via Intl_dxmedphys_wd_osu_list <intl_dxmedphys_wd_osu_list at lists.osu.edu<mailto:intl_dxmedphys_wd_osu_list at lists.osu.edu>>
Sent: Thursday, March 13, 2025 12:12 PM
To: Matt Wait <Matt.Wait at kp.org<mailto:Matt.Wait at kp.org>>
Cc: DxMedPhys List <intl_dxmedphys_wd_osu_list at lists.osu.edu<mailto:intl_dxmedphys_wd_osu_list at lists.osu.edu>>
Subject: Re: [Intl_DxMedPhys] [External] Re: EXT MSG Fwd: The New CMS Measure: Methods for Size-Adjusted Dose and Their Variabilities


Dear All,

I hope this message finds you well. There continues to be misinformation circulating within the medical community regarding the CMS eCQM on excessive radiation dose. While I want to make it clear that the medical physics community is not the source of this misinformation, it is important that we work together to stop the spread of inaccuracies and ensure that the correct information is shared.

First, I’d like to clear up the misconception that CMS requires all vendors to produce exactly the same output as Alara. This claim is factually incorrect. The idea that all vendors must replicate Alara’s results is not only impractical but also inconsistent with CMS requirements. It is important to recognize that even minor differences, such as the use of different libraries or programming languages (e.g., Matlab vs. Python), can result in small differences in output. CMS does not, and has never required, that vendors achieve identical outputs. In fact, the only direct mention of Alara in the recent clarification from CMS was to explicitly state that "hospitals and clinicians are not required to use the Alara Imaging Software for CMS measure compliance." Rather, CMS mandates that software be consistent with the measure specifications, which is the sole standard to be adhered to.

Additionally, I would like to share that Imalogix has held several discussions with CMS to seek clarification on some of the issues raised in this thread. While Alara was unwilling to share certain proprietary information, our discussions with CMS focused on how vendors could proceed using the data already available in the measure specifications. This culminated in a demonstration of the Imalogix product in December, where CMS was impressed with our capabilities. Following this demonstration, CMS issued the official clarification statement confirming that any vendor could calculate the three required data elements, provided they adhere to the measure specifications.

For reference, here is the official CMS clarification:
CMS eCQM Clarification on Excessive Radiation Dose<https://urldefense.com/v3/__https://ecqi.healthit.gov/excessive-radiation-dose-or-inadequate-image-quality-diagnostic-computed-tomography-adults-ecqm-measure-clarification__;!!KGKeukY!1DviNQ-2Vo0Wr4AOsFWhiA-Wlm33papPl7CIlwGLYXVEBHmHRMAQmvYTofxyie6iUlZ1lXBGSMQzk7oph0I_EjF1pkLwvscYq9aIP6E5_LVBQlqe$>

Additionally, for those who would like to review the full measure specifications, here is the link:
Measure Specifications – CMS<https://urldefense.com/v3/__https://www.qualityforum.org/ProjectMeasures.aspx?projectID=86057&cycleNo=2&cycleYear=2021__;!!KGKeukY!1DviNQ-2Vo0Wr4AOsFWhiA-Wlm33papPl7CIlwGLYXVEBHmHRMAQmvYTofxyie6iUlZ1lXBGSMQzk7oph0I_EjF1pkLwvscYq9aIP6E5_JJ4SK6S$>

Finally, I want to emphasize that Imalogix places a strong focus on transparency in the eCQM process. We take a different approach compared to other vendors in this space, and we provide comprehensive documentation of the formulas, values, and methods used for CMS calculations on every CT examination.

I hope this helps to address some of the confusion that has been circulating. Please feel free to reach out to me directly if you have any questions or if you'd like to discuss further. I’m happy to help clarify any points.

Thank you all for your time and collaboration.

Best regards,

Olav

On Wed, Mar 12, 2025 at 1:40 PM Matt Wait via Intl_dxmedphys_wd_osu_list <intl_dxmedphys_wd_osu_list at lists.osu.edu<mailto:intl_dxmedphys_wd_osu_list at lists.osu.edu>> wrote:

I spoke with ALARA yesterday and while they still would not disclose their “proprietary” patient size adjusted dose calculation or global noise, they did mention working with Tim Stick and Tony Siebert so I would guess this 2017 paper is closer to what they do. To hear them tell it, what CMS authorized was any vendor could take the same input and provide the exact same output as their method, which is of course functionally impossible given the proprietary nature of their calculations.



Matt Wait, MS, DABR, DABSNM, MRSE
Senior Diagnostic Physicist

Assistant Radiation Safety Officer

Assistant Residency Director

Kaiser Permanente

Southern Permanente Medical Group
Medical Imaging Technology and Informatics
4867 Sunset Blvd

Los Angeles, CA 90027

x5347 (office)

(818) 232-2427 (mobile phone)



From: Intl_dxmedphys_wd_osu_list <intl_dxmedphys_wd_osu_list-bounces+matt.wait=kp.org at lists.osu.edu<mailto:kp.org at lists.osu.edu>> On Behalf Of Zhou, Yifang (Jimmy), Ph.D. via Intl_dxmedphys_wd_osu_list
Sent: Tuesday, March 11, 2025 2:45 PM
To: Justin Solomon <justin.solomon at duke.edu<mailto:justin.solomon at duke.edu>>; Jie Zhang <jzctjmn at gmail.com<mailto:jzctjmn at gmail.com>>
Cc: DxMedPhys List <intl_dxmedphys_wd_osu_list at lists.osu.edu<mailto:intl_dxmedphys_wd_osu_list at lists.osu.edu>>
Subject: Re: [Intl_DxMedPhys] [External] Re: EXT MSG Fwd: The New CMS Measure: Methods for Size-Adjusted Dose and Their Variabilities



Another reference for global noise is from a study of Malkus and Szczykutowicz, entitled “A method to extract image noise level from patient images in CT. ”, Med Phys. 2017 Jun;44(6): 2173-2184. I second to Justin in that protocol mis-mapping

Caution: This email came from outside Kaiser Permanente. Do not open attachments or click on links if you do not recognize the sender.

________________________________

Another reference for global noise is from a study of Malkus  and Szczykutowicz, entitled “A method to extract image noise level from patient images in CT.”, Med Phys. 2017 Jun;44(6):2173-2184.

I second to Justin in that protocol mis-mapping due to naming convention or other inaccurate protocol description may be a bigger concern, not only from the global noise perspective, but also from the size adjusted DLP perspective.



Jimmy Zhou

Cedars-Sinai Medical Center



From: Intl_dxmedphys_wd_osu_list <intl_dxmedphys_wd_osu_list-bounces+yifang.zhou=cshs.org at lists.osu.edu<mailto:intl_dxmedphys_wd_osu_list-bounces+yifang.zhou=cshs.org at lists.osu.edu>> On Behalf Of Justin Solomon via Intl_dxmedphys_wd_osu_list
Sent: Tuesday, March 11, 2025 11:43 AM
To: Jie Zhang <jzctjmn at gmail.com<mailto:jzctjmn at gmail.com>>
Cc: DxMedPhys List <intl_dxmedphys_wd_osu_list at lists.osu.edu<mailto:intl_dxmedphys_wd_osu_list at lists.osu.edu>>
Subject: [External] Re: [Intl_DxMedPhys] EXT MSG Fwd: The New CMS Measure: Methods for Size-Adjusted Dose and Their Variabilities



I believe most commercial offerings that do CT global noise measurements follow some variant of this method: https: //pubmed. ncbi. nlm. nih. gov/26102424/ There are some details/parameters that could vary between implementations. Would be an



I believe most commercial offerings that do CT global noise measurements follow some variant of this method: https: //pubmed. ncbi. nlm. nih. gov/26102424/ There are some details/parameters that could vary between implementations. Would be an interesting

I believe most commercial offerings that do CT global noise measurements follow some variant of this method: https://urldefense.com/v3/__https://pubmed.ncbi.nlm.nih.gov/26102424/__;!!KGKeukY!2QT2bLWkfooa93rKRLkiKLMluUvYdYv5mISg4IQ5Tlxty-TuHY5l39fcmDWfDfvuCTp5IMtASHClxxosfjqjNGs_OHzjMx96_lVidip6fr8$ <https://urldefense.com/v3/__https:/pubmed.ncbi.nlm.nih.gov/26102424/__;!!KGKeukY!wo8RkvE8k7a3feJqhXalDEECDyEqcOCuOM5YS3bSVdbt6V2c0_wMGKXkI8zHDRIfHlhWeWhQghkXUqkFtYXfDNv2RvQQ8WUZ5K9mSIUFlXtfu4CI$>



There are some details/parameters that could vary between implementations. Would be an interesting study to compare vendors with a common dataset.



That’s said we’ve had an in house built system making these measurements for many years now. In my experience the challenging part of using those data is sorting through meta data / protocol / series naming inconsistencies when doing aggregated analysis. I’m guessing those sources of variability and uncertainty dwarf the variability due to global noise measurement implementation.



Cheers,

Justin

————————

Justin Solomon, PhD DABR

Radiation Physicist

Duke Health

919-684-1441



On Mar 11, 2025, at 9:51 AM, Jie Zhang via Intl_dxmedphys_wd_osu_list <intl_dxmedphys_wd_osu_list at lists.osu.edu<mailto:intl_dxmedphys_wd_osu_list at lists.osu.edu>> wrote:



Yes. We have also investigated global noise metrics and their potential limitations in clinical applications. We are wrapping up our writing and hope to share our results soon. Thanks! Jie On Tue, Mar 11, 2025 at 11: 32 AM Gauntt, David <davidgauntt@ uabmc. edu>

Yes. We have also investigated global noise metrics and their potential limitations in clinical applications. We are wrapping up our writing and hope to share our results soon.



Thanks!



Jie



On Tue, Mar 11, 2025 at 11:32 AM Gauntt, David <davidgauntt at uabmc.edu<mailto:davidgauntt at uabmc.edu>> wrote:

Jie,



Does your paper  address the issue of image quality?



The new CMS measure addresses both dose and image quality, using "global noise" as a measure of image quality.  However, as near as I can tell the measure does not address how you measure "global noise" in a clinical image, and have not found any papers from the measure's stewards addressing this issue.



Does anyone have any references to anything addressing how you calculate global noise?



---

David M. Gauntt, Ph.D.

Associate Professor

Division of Physics and Engineering

Department of Radiology

(205)975-3777



<OutlookEmoji-1647458080270d7f02ca5-59f0-4d92-8fab-6fcda46b3f08.png>







________________________________

From: Intl_dxmedphys_wd_osu_list <intl_dxmedphys_wd_osu_list-bounces+davidgauntt=uabmc.edu at lists.osu.edu<mailto:uabmc.edu at lists.osu.edu>> on behalf of Jie Zhang via Intl_dxmedphys_wd_osu_list <intl_dxmedphys_wd_osu_list at lists.osu.edu<mailto:intl_dxmedphys_wd_osu_list at lists.osu.edu>>
Sent: Tuesday, March 11, 2025 10:04 AM
To: intl_dxmedphys_wd_osu_list at lists.osu.edu<mailto:intl_dxmedphys_wd_osu_list at lists.osu.edu>
Subject: EXT MSG [Intl_DxMedPhys] Fwd: The New CMS Measure: Methods for Size-Adjusted Dose and Their Variabilities



Thanks to Dr. Wunderle! I originally posted this to the old listserver and am now forwarding it to the new Dx list. I am sorry if you receive it twice. Jie ---------- Forwarded message --------- From: Jie Zhang <jzctjmn@ gmail. com> Date: 

Thanks to Dr. Wunderle! I originally posted this to the old listserver and am now forwarding it to the new Dx list.  I am sorry if you receive it twice.

Jie

---------- Forwarded message ---------
From: Jie Zhang <jzctjmn at gmail.com<mailto:jzctjmn at gmail.com>>
Date: Tue, Mar 11, 2025 at 9:15 AM
Subject: The New CMS Measure: Methods for Size-Adjusted Dose and Their Variabilities
To: DXIMGMEDPHYS at HERMES.GWU.EDU<mailto:DXIMGMEDPHYS at HERMES.GWU.EDU> <dximgmedphys at hermes.gwu.edu<mailto:dximgmedphys at hermes.gwu.edu>>



Dear Colleagues,

The new CMS guidance on excessive radiation measurement allows flexibility in software selection, but this may lead to inconsistencies and undermine its goal.

We recently evaluated five methods for estimating effective diameter and their impact on Size-Specific Dose Estimate (SAD) in thoracic and abdominal CT. A retrospective analysis of 719 exams revealed inconsistencies in SAD methods, dose thresholds, and application across patient populations and institutions. Addressing these issues is critical for accurate dose reporting and diagnostic integrity.

Our manuscript is available on arXiv: https://urldefense.com/v3/__https://arxiv.org/abs/2503.06644__;!!KGKeukY!2QT2bLWkfooa93rKRLkiKLMluUvYdYv5mISg4IQ5Tlxty-TuHY5l39fcmDWfDfvuCTp5IMtASHClxxosfjqjNGs_OHzjMx96_lViRFXyalo$ <https://urldefense.com/v3/__https:/arxiv.org/abs/2503.06644__;!!KGKeukY!wkvI7i3VRXaaElI73WdyPRf_Zk6qQqZ2CCRW0BoG-aYbTN1bVG_WIFbTeFOBYzuVEpUvax1OJJGkFDM4g68KPmxld3yXDnHKjwB6aQ$>.

Our findings reinforce concerns raised by the AAPM Commissioned Panel, recently published in AJR, and we hope to provide a technical perspective on the CMS measure.

Best Regards,

Jie

Jie Zhang, PhD, DABR (D, N), FAAPM

Professor of Radiology and Biomedical Engineering

Chief, Division of Diagnostic & Nuclear Medical Physics

Program Director, Diagnostic Imaging Physics Residency

Department of Radiology

University of Kentucky College of Medicine

UK HealthCare

800 Rose Street, Room HX-307

Lexington, KY 40536-0293

Phone: (859) 323-2954

Email: jnzh222 at uky.edu<mailto:jnzh222 at uky.edu>




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