The first incentive checks are being delivered under CMS’s meaningful use program for electronic health records. But for many radiologists, the program is just now coming into focus. Here's what you should be doing now.
The first incentive checks are being delivered under CMS’s meaningful use program for electronic health records. But for many radiologists, the program is just now coming into focus.
Keith Dreyer, DO, PhD, FSIIM, vice chair of radiology informatics at Massachusetts General Hospital and corporate director of enterprise medical imaging for Partners Healthcare in Boston, said a good amount of practices aren’t prepared to take advantage of the incentives or are unaware of the program.
But it is time to prepare. More than 90 percent of radiologists are considered eligible professionals, Dreyer said, which means they could receive up to $44,000 for implementing and meaningfully using an EHR. A few years down the road, that incentive will become a penalty.
It’s no wonder it’s been slow to catch on for specialists. The criteria developed to prove meaningful use were developed with primary-care physicians in mind, said Michael Peters, the American College of Radiology’s director of legislative and regulatory affairs. CMS outlined 15 core objectives providers must meet, as well as a menu set of 10 objectives, from which they can select five.
“The good news is the CMS rule at least provides a degree of flexibility to a certain extent, although for radiology it’s still jamming a square peg in a round hole,” Peters said.
Luckily, radiologists aren’t expected to comply with all of the objectives. I Several objectives include exclusion criteria for specialists. For example, if an eligible provider writes fewer than 100 prescriptions during a reporting period, the provider is exempt from the e-prescribing, computerized provider order entry, and drug formulary check measures, according to the ACR.
In the core objectives, several measures may be excluded, including three specific to radiologists. Here are the remaining objectives that do not have exclusion criteria:
• Implement drug-drug and drug-allergy interaction checks.
• Maintain and up-to-date problem list of current and active diagnoses.
• Maintain an active medication list
• Maintain an active medication allergy list
• Record patient demographics, such as gender, race, and ethnicity
• Report ambulatory clinical quality measures to CMS
• Implement one clinical decision support rules relevant to specialty along with ability to track compliance with that rule
• Ensure capability to exchange key clinical information among providers and patient-authorized entities
• Protect electronic health information
The menu set of objectives also includes exclusions. Here are those that do not:
• Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research and outreach
• Use certified EHR technology to identify patient-specific education resources and provide those to patients if appropriate
For an expanded list of the objectives, and reasons for exclusions, see ACR’s chart here.
Here’s the catch. Although CMS’ rule might be flexible, that same leniency isn’t reflected in the rules from the Office of the National Coordinator (ONC), which set the standards for the technology used to meet meaningful use. Officials there determined that technology must include a certified EHR or a combination of certified EHR modules, not just PACS technology.
Some of the criteria that the technology must meet to be certified would have been a part of these excluded items for radiologists, Peters explained. For example, radiologists might be excluded from e-prescribing under the CMS regulations, but they still have to acquire technology that is certified for e-prescribing.
That’s because ONC wants “all participating doctors to have technology with the same baseline requirements that they can build on for future stages of meaningful use,” Peters said.
Another major challenge? The vendors have been slow to get their product certified, Peters said. This could be because some smaller companies haven’t been following the news, or that there is a need for radiology technology regardless of certification status.
In fact, it wasn’t until last fall that radiology vendors really woke up the fact that they should be making moves to certify their technology, said Dreyer. They then have started going through their portfolio to determine what products can be certified and what their customers want, he said. The path will be easier for radiologists practicing in a larger hospital that is applying for the meaningful use incentives. There, radiologists have the opportunity to weigh in with their needs and modify the EHR appropriately.
Including Computerized Decision Support in Meaningful Use
With an eye toward cost savings and quality improvement, why not include computerized decision support (CDS) in the meaningful use program? That’s what CDS advocates would like to see in the second stage, raising interest in the trend now with the hopes that it will be required down the road.
Decision-support systems use algorithms to guide clinicians to better imaging exams at the point of order. A pilot program in Minnesota has shown the number of high-tech scans didn’t increase, while the quality of the image did improve and efficiencies saved $84 million in healthcare costs.
“If you’re using CDS, then you have gone through a decision tree that is physician-friendly, and it has been confirmed through a peer-reviewed, evidence-based algorithm that this indeed is the appropriate diagnostic test of the patient,” explained Liz Quam, founding member of the Imaging eOrdering Coalition and director of the Center for Diagnostic Imaging Institute.
One objective in the first stage of meaningful use does require the capability for clinical decision support, but it’s not medical imaging-specific and it doesn’t require it for all imaging. CDS, Quam argued, should be a part of the meaningful use criteria, and idea she said has been met with great interest by government representatives. "Why not kick-start the use of CDS by requiring it in Phase Two?” - Sara Michael
For the average radiology practice, there are two things you need to know, according to Jonathan Berlin, a radiologist at Northshore University Health Center and associate clinical professor of radiology at University of Chicago Pritzker School of Medicine: “Number one, this is on the horizon, and number two, it’s not something they can blow off.”
Today, the government is offering incentives, but in 2015, that turns into a penalty, he noted. In 2015, physicians face a 1 percent cut from Medicare, which will rise to an up to 5 percent cut in 2019 and beyond.
“This is something they have to pay attention to because it will eventually affect their Medicare reimbursement,” Berlin said.
What should you be doing now? Here’s what the experts say:
• First, get familiar with the program. Dreyer suggest you review the information available from the ONC, as well as the ACR, which has done well to interpret the rules for radiology professionals. There’s also radiologyMU.org, which is providing diagnostic imaging-specific guidance, including a tool that allows you to analyze your practice to help you make moves toward meaningful use.
• Register for the program. Starting on January 3, providers could sign up for the program with CMS, even if they aren’t ready to start proving meaningful use. Peters said that you can begin the 90-day period of attestation for the program in 2012 and still be eligible for the full incentive, just as you would if you participated this year.
• Contact your IT vendor. Berlin suggested practices ask their vendors if they are familiar with meaningful use, whether the product is certified, and what they are doing to ensure their systems will be complaint with the program. Dreyer expects many RIS vendors will have gone through the modular certification program by about April, which will potentially begin a flurry of action for imaging technology vendors.
• Hospital-based radiologists should be reaching out to hospital administrators, Berlin said. How can they participate in the process? “There is value in radiologists knowing the generalized framework [of meaningful use]” so they can have a seat at the table with hospital officials, he said.
• Get involved. Liz Quam, executive director of the CDI Quality Institute at the Center for Diagnostic Imaging and member of the Imaging eOrdering Coalition which promotes computerized decision support, said practices should stay connected so they can mold the regulations to best fit the industry. “It’s going to continue to evolve,” she said. Take for example the first release of meaningful use, which has since changed considerably. Many providers would have given up hope of being able to meet the requirement, but instead, groups have been actively engaged with regulators and helped bring about the changes.
• Consider the impact this shift will have on your practice. Implementing new technology – and documenting its use - will change many of your processes. At MGH, officials mapped out the workflow, Dreyer said, adding, “This has to be thought through with practices.”
For more information on the program and tips for getting ready, check out Dreyer’s recent article here and Diagnostic Imaging’s Meaningful Use Resource Center.