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Create Policies for Meaningful Use Exclusions

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Radiology departments should create policies for meaningful use criteria exclusions, and document the rationale, experts at SIIM said.

ORLANDO, FL - To achieve meaningful use of health IT under the federal government’s incentive program, radiologists can be excluded from several of the criteria. But a few of the measures - and whether they are not core to radiology and therefore can be exempt - are up for debate.

Take for example, recording vital signs. It’s one of the criteria providers can exclude, as long as they show the height, weight, and blood pressure of their patients have no relevance to their scope of practice.

“It’s very difficult to say there is no relevance” of patient vital signs, said Alberto Goldszal, MBA, PhD, CIO of the University Radiology Group, speaking at a SIIM 2012 session Thursday. He continued to say that even in this era of dose tracking, there are other proxies radiologists use rather than weight, such as shape and size profiles for the patient, that would render these vital signs irrelevant for many studies.

But, he added, “It is relevant for a few studies for sure.”

Under the first stage of the meaningful use program, there are 15 core measures, six of which are eligible for exclusion by specialists. There’s also a so-called menu set of measures, of which providers can choose five out of ten to meet achieve meaningful use. Eight of these are eligible for exclusion. “With a little bit of strategy, you can begin to pare this down and make it a little more manageable,” said Arun Krishnaraj, MD, MPH, of Massachusetts General Hospital, speaking at SIIM.

But a few of these criteria are stirring up some questions among radiologists. With the vital signs, what, if any, are the legal implications of collecting that data, for example, even if it’s not used? Similar debates are being raised when it comes to two more tricky criteria: defining office visits and defining a patient encounter (that the patient was “seen by” the eligible physician). Nine of the measures use the term “seen by” the EP, so if a radiologist determines he or she is not actually seeing the patient those measure could be excluded, said Keith Dreyer, DO, PhD, FSIIM, of Massachusetts General Hospital, speaking at the SIIM session.

“There’s healthy debate here,” he said of this language.

The solution? Make a determination and create policies and documentation that support justify it, Dreyer said. “Create policies in radiology.”

Goldszal echoed the sentiment. Remember there’s always possibility of an audit. “Create a policy, document your rationale for all discretionary actions and document your results,” he advised.

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