[Intl_DxMedPhys] [Non-DoD Source] Fwd: [AMRSO] FW: Urgent help needed on the comment to the new CMS proposition

Thu Sep 11 18:12:13 EDT 2025

I have some different concerns that I would like to submit as comments, but I am unsure what “comment category” to select on the submission page. Anyone know?

For everyone’s consideration… some additional thoughts I want to convey in my comments include the following:

  *   Size Adjusted Dose (SAD) uses DLP as an input, and in turn is based on CTDI. If CMS mandates this, we will be hardcoding a concept that is already questionable for cone-beam and wide beam CT. This will be a bigger problem with time.

  *   Facilities already have a reason to want to produce quality images. We really don’t need an overly simplistic metric to motivate clinics. The idea that it might prevent a race-to-the-bottom for dose has some merit. But who is to say that facilities don’t simply report based on a recon that suppresses high spatial frequencies with radiologists reading different recons?

  *   It might make sense to have voluntary reporting of just dose metrics beginning in 2027 with facilities getting to pick either SSDE or SAD. At a later date (e.g. 2030 and on) reporting using any AAPM or ACR approved dose metric applicable to the specific technology could be considered.

Scott Winter

From: Intl_dxmedphys_wd_osu_list <intl_dxmedphys_wd_osu_list-bounces at lists.osu.edu> On Behalf Of Adam Springer via Intl_dxmedphys_wd_osu_list
Sent: Wednesday, September 10, 2025 9:17 PM
To: kenharper14 via Intl_dxmedphys_wd_osu_list <intl_dxmedphys_wd_osu_list at lists.osu.edu>
Subject: [Non-DoD Source] [Intl_DxMedPhys] Fwd: [AMRSO] FW: Urgent help needed on the comment to the new CMS proposition

I saw this post on the AMRSO list but I don’t recall it being discussed on this list. I figure many will be interested. -Adam Begin forwarded message:  Hello All – just a reminder about the comment period deadline for the CMS proposed rule
I saw this post on the AMRSO list but I don’t recall it being discussed on this list. I figure many will be interested.

-Adam

Begin forwarded message:

Hello All – just a reminder about the comment period deadline for the CMS proposed rule change on CT dose reporting.  All of this information was compiled and provided by a medical physicist colleague.  Comments from individuals who are technically qualified will carry a lot of weight.

-Tara

Dear Colleagues,

We would like to have your attention and help with a critical CMS proposition which is currently open for public comment until Sep 15th. Please see the detailed instruction in the attached documents about the fundamentally flawed measure, which was proposed by a for-profit company and opposed by all major professional societies including RSNA, ACR, AAPM, ASRT and HPS.

The current proposition to be commented on is to set the data reporting for this measure to be Permanently Voluntary.  Therefore, we are strongly in support of this proposition, while the for-profit company is also carrying an overwhelming campaign over social media by using disguising weblinks such "ucsf.us" instead of "uscf.edu".

If you are not familiar with this measure (and the current proposition to make it optional), please refer to the sample texts either in this email below or in the attached sample letter.

To save everyone’s time, one way is to provide some simple versions of comments (we include several examples below in this email and also in the attached instruction document). Anyone can directly copy/paste, and submit quickly on the website: https://urldefense.com/v3/__https://www.regulations__;!!KGKeukY!zP4kvRiMWMmsXp_bSw7qPvu42GH2XftHOGRpmLXP7UBIEh-KE6Fq94bf9nX-ZxPj4KcpqWE33d_epNdyZPyh-OWTJOgAJYO3K3s7x_Pp1DEEgTIQliDs$ .<https://urldefense.com/v3/__https:/secure-web.cisco.com/1hSy6k9zrdAPTLR1oDl61VKQAtYRsfpmkl8u3zplpojnwSylMTEZWltisG-bHkqXATG1Y22TIvf645q8MDOnHBkMtXKMLgYNQzONvZfs3RWf300cPRjCR7TG2ad239owN7g_dknEYs9Dl6u2SFTfX0ZKWfiTr3-zTZksKVCn88xjXB5BlD-h1q7sqKJR657BxP1gEQn9QQkvXQNDAcxVryCVCjSvdcTEG8V90xH46-LZQ2PeaD-S6oKV4jgDehEnL_xea1R2CXrms2WYzKRpMZl4bFkRwRtYbEW9sQ8MkPICVh78GwOkL6K2P9rq3xMIU/https*3A*2F*2Fwww.regulations.gov*2Fcommenton*2FCMS-2025-0306-0002__;JSUlJSU!!KGKeukY!0hWFh0hvSnArkmV9Q9QAzzhqk1PsEnPjbi74o_jzwcOuvkiordlZ2_jsAWqsffwN3RV8G_K-_WB6aw3sxwCNPf5eUCvMrfq-6OagYw$>g<https://urldefense.com/v3/__https:/secure-web.cisco.com/1hSy6k9zrdAPTLR1oDl61VKQAtYRsfpmkl8u3zplpojnwSylMTEZWltisG-bHkqXATG1Y22TIvf645q8MDOnHBkMtXKMLgYNQzONvZfs3RWf300cPRjCR7TG2ad239owN7g_dknEYs9Dl6u2SFTfX0ZKWfiTr3-zTZksKVCn88xjXB5BlD-h1q7sqKJR657BxP1gEQn9QQkvXQNDAcxVryCVCjSvdcTEG8V90xH46-LZQ2PeaD-S6oKV4jgDehEnL_xea1R2CXrms2WYzKRpMZl4bFkRwRtYbEW9sQ8MkPICVh78GwOkL6K2P9rq3xMIU/https*3A*2F*2Fwww.regulations.gov*2Fcommenton*2FCMS-2025-0306-0002__;JSUlJSU!!KGKeukY!0hWFh0hvSnArkmV9Q9QAzzhqk1PsEnPjbi74o_jzwcOuvkiordlZ2_jsAWqsffwN3RV8G_K-_WB6aw3sxwCNPf5eUCvMrfq-6OagYw$>ov/commenton/CMS-2025-0306-0002<https://urldefense.com/v3/__https:/secure-web.cisco.com/1hSy6k9zrdAPTLR1oDl61VKQAtYRsfpmkl8u3zplpojnwSylMTEZWltisG-bHkqXATG1Y22TIvf645q8MDOnHBkMtXKMLgYNQzONvZfs3RWf300cPRjCR7TG2ad239owN7g_dknEYs9Dl6u2SFTfX0ZKWfiTr3-zTZksKVCn88xjXB5BlD-h1q7sqKJR657BxP1gEQn9QQkvXQNDAcxVryCVCjSvdcTEG8V90xH46-LZQ2PeaD-S6oKV4jgDehEnL_xea1R2CXrms2WYzKRpMZl4bFkRwRtYbEW9sQ8MkPICVh78GwOkL6K2P9rq3xMIU/https*3A*2F*2Fwww.regulations.gov*2Fcommenton*2FCMS-2025-0306-0002__;JSUlJSU!!KGKeukY!0hWFh0hvSnArkmV9Q9QAzzhqk1PsEnPjbi74o_jzwcOuvkiordlZ2_jsAWqsffwN3RV8G_K-_WB6aw3sxwCNPf5eUCvMrfq-6OagYw$>.

The submission itself only took 1 minute. We encourage everyone to submit individually, either from these simple options or upload a more formal letter using the letter template attached.

Simple Version 1:

I am writing to comment on the proposed rules (CMS-1834-P) regarding the Hospital Outpatient Quality Reporting (OQR) Program, specifically on the proposed change to “Excessive Radiation Dose or Inadequate Image Quality for Diagnostic Computed Tomography (CT) in Adults” (CMS eCQM ID: CMS1074v1). I strongly support CMS’s proposal to make this quality measure voluntary in 2027 and beyond. The two major metrics in the eCQM, Calculated CT Global Noise and Calculated CT Size-Adjusted Dose, are fundamentally flawed. They do not reflect how radiologists assess image quality or how physicists measure and calculate radiation dose. They are inconsistent with some of the internationally recognized standards such as Size Specific Dose Estimate (SSDE). Enforcing fixed limits creates an untenable situation for some patient types that will lead to inferior diagnostic information and missed or incorrect diagnoses. Making the rule voluntary in 2027 and beyond will give time to professional organizations and CT imaging community to determine more valid metrics that truly monitor diagnostic quality and patient outcomes.

Simple Version 2:

This comment is regarding the proposed rules (CMS-1834-P), particularly on the proposed changes to the eCQM titled “Excessive Radiation Dose or Inadequate Image Quality for Diagnostic Computed Tomography (CT) in Adults” (CMS eCQM ID: CMS1074v1). I strongly support the proposal to make this rule voluntary at 2027 and beyond. The measure’s core metrics, “Calculated CT Global Noise” and “Calculated CT Size-Adjusted Dose”,  have not received broad and strict validation in the clinical and scientific community. This measure relies on use of a software tool that has been developed and is to be provided by a for-profit company, and that same company is the proponent of the measure. This is an inherent conflict of interest. Before the rule becomes mandatory, CMS should require independent studies, peer-reviewed evidence, and multiple implementation options. Making it voluntary at 2027 and beyond is the right thing to do.

Simple Version 3:

This comment is about CMS-1834-P and the recently proposed changes to eCQM CMS1074v1: Excessive Radiation Dose or Inadequate Image Quality for Diagnostic Computed Tomography (CT) in Adults. I strongly endorse the proposed change to make it voluntary in 2027 and beyond. The implementation in the original rule depends on ALARA Imaging, which is a new (2020), for-profit startup company with no track record of having previously performed any project on imaging, let alone a project of such wide scope, scientifically or technically. Sufficient time has not been allowed for testing with this company or for alternative companies to develop products that would allow a practice to comply with this measure. A voluntary period will allow careful further validation studies, fair competition among different commercial or academic tools, and simpler workflow before the rule becomes mandatory.

Simple Version 4:

I am writing to comment on CMS-1834-P and the recently proposed changes to eCQM CMS1074v1: Excessive Radiation Dose or Inadequate Image Quality for Diagnostic Computed Tomography (CT) in Adults. I strongly endorse the proposed change to make it voluntary in 2027 and beyond. Since the mandatory requirement imposes unnecessary regulatory burden and increase operational costs without corresponding improvements in patient care or system efficiency.

While the goal of improving transparency and quality in hospital outpatient and ambulatory surgical center payments is commendable, some provisions appear overly complex and administratively burdensome. These requirements could divert critical resources away from direct patient care and create additional compliance challenges for healthcare providers.

I urge regulators to carefully consider the cost-benefit balance of these requirements and explore opportunities to streamline reporting and documentation processes. Minimizing unnecessary regulatory burden is essential to fostering innovation, reducing administrative overhead, and ultimately improving healthcare delivery.

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