Like many others, we are now exploring how radiologists may benefit from the EHR incentive program. Our interest is sparked by the fact that for all physicians, CMS will pay cash incentives to eligible health care professionals who make “meaningful use” of certified EHRs. But maybe even more eye-opening is the fact that those who are eligible but don’t meet the requirements will find CMS payments reduced starting in 2015.
Like many others, we are now exploring how radiologists may benefit from the Electronic Health Record (EHR) incentive program. Our interest is sparked by the fact that for all physicians, CMS will pay cash incentives to eligible health care professionals who make “meaningful use” of certified EHRs.
But maybe even more eye-opening is the fact that those who are eligible for the program but don’t meet the requirements for meaningful use will find CMS payments reduced starting in 2015.
At first blush, it seemed that radiology, as a primarily hospital-based service, would not benefit much from this program, since it was for incentives in the non-hospital setting. But for those of us who do a substantial amount of work outside a hospital setting, determining whether you are eligible is an important first step.
First, check out the rules. We looked at the rules and found that hospital-based physicians cannot participate in the program and will not feel the impact of the reimbursement penalties that begin in 2015. CMS considers a physician hospital-based if more than 90 percent of their services billed to Medicare annually use the place-of-service codes for hospital or emergency department. All other physicians can participate, including radiologists practicing in an imaging center or other outpatient setting.
For Medicaid incentives, 30 percent of encounters during any ninety day period need to be for Medicaid. For Medicare there is no minimum needed. Payments are based on a percentage of total charges up to an annual maximum. So you can receive a portion of the bonus even with very low volume.
The next step is to start looking at the specifics of how to satisfy the requirements. The government sets out a group of criteria for meaningful use of a certified EHR. A part of those are core and required of all participants. The core criteria are things such as recording patient demographics in the EHR to reporting ambulatory clinical quality measures electronically. Importantly for radiologists, some of the criteria may be exceptions and therefore aren’t necessary for certain specialties.
Take a look at the core criteria. Are you satisfying some? Can you document it? If you can’t document it, it doesn’t count, so make sure the electronic system is capturing and storing the data you need. If it isn’t you may need to work with your facility to make sure the data is captured. Emphasize to them the import to your practice and its health, and that keeping you healthy is best for them too.
Additional criteria must be selected from a menu CMS provides. These criteria include using the EHR to generate lists of patients by specific conditions, identifying patient-specific education resources, providing a summary care record for each transition of care and referral and so on.
The list is a little intimidating, especially for a small group. So have your administration gather this list. Review which criteria are easily attainable, and focus first on them. Then arrange them in order of which are easiest to satisfy. Again, recall that you need to both satisfy the requirements and document that you have.
Decide How Painful Cuts May Be
If there are those in the practice who don’t think it wise to participate, there are important considerations. It isn’t just that you will give up on incentives. You may cost the practice revenue.
The penalty for not participating may start with a 1 percent reduction of Medicare payments in 2015, but the Secretary of HHS has the authority to increase it to as much as 5 percent. Radiologists who are eligible, but don’t participate, will feel the brunt of these penalties.
So, ask you practice manager to do a few calculations. You can quickly find out how much your practice stands to lose, either on the low side or high side of the equation. You’ll then know what’s at risk, and be able to make an informed decision about how to proceed.