Dr. Shrestha is the Vice President of Medical Information Technology, University of Pittsburgh Medical Center, Pittsburgh, PA, and the Medical Director, Interoperability & Imaging Informatics, Pittsburgh, PA.
Wouldn’t we all like to have a slice of the $1.5 billion incentives
payment pie available for eligible radiologists? Imaging was given the
cold shoulder in the first phase of the meaningful use program
(MU), but the Stage 2 MU proposal gives more credit to radiology. The
question is, is it enough? And what are providers to do now? The
recommendations incorporated into the proposed rules by the Centers for
Medicare &Medicaid Services (CMS) and the Office of the National
Coordinator (ONC) for Health IT include a menu set measure for
diagnostic image accessibility, clinical quality measures relevant to
radiology, and more flexibility on defining encounters. But for a
clinical specialty that isso integral to the running of a health system,
radiology measures are only deemed optional.
Personally, I find
this bittersweet. While we are happy that imaging is finally getting a
decent mention, it’s only that – a decent mention.Many in the industry
had been hoping that imaging would be deemed ‘required,’ and not just
The Health Information Technology for
Economic and Clinical Health (HITECH) Act is a key component of the 2009
American Recovery and Reinvestment Act (ARRA) – more fondly known as
the ‘Stimulus Bill.’ This Act seeks to improve American healthcare
delivery and patient care through an unprecedented investment in health
information technology (David Blumenthal, 2010). MU aims to improve
health outcomes, patient engagement, care coordination, and efficiency
of the healthcare system by promoting the adoption and meaningful use of
health information technology electronic health records (EHR) incentive
programs. MU is divided into 3 stages:
- Stage 1 focuses on capturing health information in a coded format to track key clinical conditions, to communicate information for care coordination, and to identify some clinical quality measures.
- Stage 2 (starting in 2014) expands on Stage 1 criteria and encourages use of captured data and exchange of key electronic information in a structured format. Viewing of images will be supported as an optional item.
- Stage 3 (starting in 2015) would focus on achieving improvements in quality, safety, and efficiency, emphasizing decision support, patient access to self-management tools, and population health.
Get with the program
The establishment of incentive
payments to eligible professionals (EPs) and hospitals to promote the
adoption and MU of interoperable health information technology and
qualified EHRs is seen as a boon to the evolving digital healthcare
enterprise. As we all strive to move the needle toward transformed
healthcare, the challenge often is in achieving true MU of health data
amid a sea of information systems and data repositories comprising
structured data, unstructured data, and imaging data.
MU has had a
series of positive impacts in the effective use of information to
support better decision making and more effective care processes that
improve health outcomes and result in robust quality measurement and
However, with reports that half of U.S. hospitals are
at risk of failing to meet federal requirements for achieving MU of
electronic medical records and may incur penalties by 2015 (Accenture,
2012), much still needs to be done.
So, indeed, MU does have
direct applicability to radiologists, and embracing this is not just an
option. At stake is more than just the$44,000 per physician for
achieving MU before 2015. The benefits of creating a more integrated
imaging workspace with richer interaction around patient-centric data
are critical to an efficient radiology workflow regardless of MU
mandates. Just as critical is that, starting in 2015,the carrot turns
into a stick, and actual Medicare payment reductions will be put in
place for not demonstrating MU.
MU and radiology:Objectives and measures
important to understand the objectives, thresholds for compliance, and
the clinical quality measures associated with MU. For example, Stage 1
of MU has 25 MU objectives or goals, 15 of which are core objectives and
10 are menu set objectives. Twenty objectives in all must be satisfied
or determined not applicable. Each MU objective has an associated
measure and reporting requirement. Some also have potential exclusions.
Radiologists will find that some CMS prescribed objectives do not apply
to outpatient imaging.
Core objectives that many will find
appropriate include drug and allergy interaction checks, demographics,
active medication allergy list, providing patients with electronic
copies of their health information, the capability to exchange key
clinical information and protect electronic health information.
for Menu set objectives, 5 objectives must be chosen from the 10 menu
set objectives (eg, lab results, patient specific education, etc).Not
all objectives are relevant for radiology (eg, drug formulary checks)
and 5 menu set objectives may be excluded if they do not apply.
there are the measures. Ambulatory quality measures are typically
referred to as “clinical quality measures” or CQMs. There are44 CQMs,
and CMS requires reporting on 3 core or alternate core measures and 3
menu set measures. Most of the Stage 1 core and menucriteria are
preserved in Stage 2, although several are combined and modified. For
example, in Stage 2, EPs will need to meet 12 out of 125clinical quality
Stage 2 of MU has incorporated many of the American
College of Radiology’s (ACR) recommendations, acknowledging the average
radiologist’s lack of regular patient contact and creating more
flexibility in the way radiologists can demonstrate MU of certified EHR
Interoperability and access
One of the main themes of MU
Stage 2 is interoperability – the demonstration of actual connection to
outside systems rather than just establishing the capability to
connect. There is a greater push for collaboration between EHR vendors,
and for improvement in care coordination, especially during transitions
of care or referrals. Also emphasized is enabling patients to access
their health information online,which may give personal health records
(PHR) and patient portals a much needed shot in the arm. Stage 2
proposes that eligible providers(EP) must show that 10% of patients
“view, download or transmit” their electronic personal health
information (ePHI). The proposed Stage2 optional imaging menu set rule
will require that more than 40% of all scans and tests ordered by EPs or
hospitals are accessible through certified EHR technology.
What do I do next?
While CMS regulates healthcare
providers, the ONC regulates the technology and the certification
process. CMS states that the EHR incentive payments will be made
available to eligible professionals who meaningfully use qualified EHRs
that have been certified by an organization recognized by the ONC.
you have not started looking at how MU would affect you, then you
should hurry up. The later you start, the more requirements you have to
meet in a shorter period of time. Remember, Medicare payment penalties
begin in 2015 for eligible professionals that fail to achieve MU status.
remember as you read this that providers across the country have
already started to see payments come through. The earlier you become
certified, the more time you have to develop compliance with various
criteria to move through the stages. Early adopters gain more immediate
and longer-term benefits for participating in the Medicare EHR program.
One can, however, begin as late as 2014 and still receive incentives for
Stage 1 compliance. The last date to attest without penalties will be
Keep in mind, however, that Certification and MU are
not the same thing. Certification is what the EHR can do; MU is how the
EHR is used – and this is the responsibility of providers and
facilities. You will not achieve MU and obtain the incentives only by
implementing a certified EHR. You must show you are using the certified
EHR technology in a meaningful way.
Physicians performing <90% of their
service in in-patient or in emergency care settings at hospitals are
eligible for incentive payments under the Medicare EHR Incentive
Program. Most radiologists are defined as eligible providers under the
Medicare and Medicaid EHR Incentive Programs.
Radiologists must use technology
certified by the Authorized Testing and Certification Body (ATCB) to
collect and disseminate health information electronically. If you have
not done so already, check with your radiology information system (RIS)
and picture archiving and communication system (PACS) vendors, as well
as with any EMR solutions you may access regularly to see where your
vendors are in the certification process. Remember, too, that the
technologies can be certified as complete or modular, and there are
provisions that allow for a shopping cart of modules as opposed to using
a complete EHR, which may be beneficial to some radiologists. A
radiologist must demonstrate MU for 90consecutive days in the first
reporting year and full years for subsequent periods to qualify for the
incentive payments. MU Stage 2 proposals include changes to
certification for EHRs sold by vendors or self-developed by healthcare
providers and new patient safety criteria for certification.
Registration and attestation
Complying with the program
costs time and money. You must register with CMS and attest to MU to
receive any incentive payments. Although certified EHR technology need
not be in place before registering, it must be in place before
attesting. Assembling the reporting datais no small feat, but make sure
you enter the data in the Meaningful Use Attestation Calculator first
(http://www.cms.gov/apps/ehr/) to see if attestation passes CMS
criteria. The registration and attestation system can be found at
RadiologyMu.org has a “practice
analyzer,” among a host of other useful information. Based on
information entered about the practice, it calculates eligibility,
incentive payments, and penalties.
It is critical to plan your MU strategy
thoroughly. Create a cross-functional team of key stakeholders that
includes EP radiologists as well as administrators, business, and IT
leads. Radiology technologists also play a key role in defining the
workflows and bridging the perceived or actual gaps in data collection
and access. This is true, too, for front office staff and PAs. As
mentioned earlier, make sure your existing (or new) RIS, PACS, and EMR
vendor is also heavily engaged. As with all major projects, ensure you
create a thorough project and communications plan, and engage all
Farzad Mostashari, MD, National Coordinator
for Health Information Technology, calls 2012 the “Year of Meaningful
Use” – with the aim to get 100,000 healthcare providers paid under the
incentive programs by year’s end (Mostashari, 2012). Increasing the
adoption andMU of healthcare IT is crucial to moving the needle toward
safer, better-coordinated patient-centered care.
MU should not be
seen as just a financial incentive but rather as a major milestone that
helps define a successful EHR implementation.
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