Achieving Meaningful Use in Radiology
A revision in the U.S. EHR Incentive Program has allowed radiologists to partake in the financial incentives for meaningful use of a certified EHR. However, now that radiologists can attest to meaningful use, there is now a process to better understand what is included in Stage 1, which involves more patient data. Also, there are discussions on how radiology as a specialty can be better represented in Stage 2.
While radiologists were initially excluded from the Medicare and Medicaid EHR Incentive Program for meaningful use (MU) of a certified EHR, revision to an outpatient services code now allows radiologists to qualify for MU like other specialists.
On April 15, 2010, the Continuing Extension Act (H.R. 4851) redefined what constitutes an eligible professional (EP) and eligible hospital (EH). Previously, the place of service (POS) Code 22, outpatient hospital, was part of an EH status. It is now part of EP. The POS Codes 21 (inpatient hospital) and 23 (emergency room) now represent all EH activities. Therefore, today, unless a physician's practice is more than 90 percent inpatient and emergency room services, he or she is considered an EP.
Through calculations from the Centers for Medicare & Medicaid Services (CMS), this revision represents approximately 84 percent of all physicians, and the American College of Radiology (ACR) estimates that it represents more than 95 percent of all radiologists.
With more than $1.5 billion available in federal incentive payments for radiology professionals, approximately 95 percent of all radiologists nationally are qualified for up to $44,000 in meaningful use incentives before 2015. To receive these incentives, radiologists must begin using a certified EHR by next year. If an organization does not comply by 2015, it will be penalized through reduced government reimbursement.
Despite the revision by CMS, one big question remains: If a radiologist must prove meaningful use of an EHR by next year, does that mean he or she needs to purchase an EHR to comply with meaningful use? The answer: If a radiologist can attest to meaningful use of a certified EHR through the provider organization he or she works with, than it can be done there.
CMS said that as of late August, approximately 90,000 eligible physicians, healthcare professionals and hospitals had registered for meaningful use with EHR incentive payments totaling $397,366,554. The Congressional Budget Office estimates that 90 percent of physicians and 70 percent of hospitals will use EHRs by 2020 and benefit from the incentive program.
Keith Dreyer, DO, PhD, vice chair of radiology at Massachusetts General Hospital in Boston, and chair of the IT government relations committee at the ACR has been actively involved in educating his colleagues, the healthcare industry, the Office of National Coordinator of Health IT and legislators about meaningful use and how radiologists can best qualify for incentive payments.
Radiologists and their practices are unique from other specialties, Dreyer says, as they are able to tag MU through their hospital or health system. "Unlike other specialties, radiologists, for the most part, don't purchase the technology they use. Most radiology practice purchases are done by someone other than the radiologist, typically the CMIO or CIO."
Radiologists who practice in a hospital are finding a lack of assistance from the provider. If a hospital determines it cannot provide assistance to the radiologists for whatever the reason, the radiologist needs to move forward with a plan, Dreyer says.
"We need to enlighten CMIOs and CIOs to create technology that is above and beyond the common technologies found in radiology [e.g., PACS, RIS]. If the radiologist needs to add a patient's height and weight, then that needs to be in there to receive the incentive payments," he says. "There is so much misinformation out there because of all of the activities and rulings. You can't change the regulation; however, it is equally important that CMIOs and CIOs respond to the pleas of the radiologists and include them in their hospital's meaningful use attestations whenever possible."
In addition to the assistance that radiologists require, Dreyer says there needs to be additional thought given to extending some of the functionality commonly found in RIS and PACS for radiologists to comply with meaningful use requirements.
The effect of meaningful use on radiology is that RIS and PACS need to evolve into what Dreyer calls, "an EHR solution." What's needed is for the RIS and PACS vendors to establish a modular certification, and build on that.
From the perspective of Alberto Goldszal, MBA, PhD, CIO at University Radiology in East Brunswick, N.J., "there is now flexibility regarding EHR implementations for radiology. We have an EHR, and if we comply with the meaningful use metrics—even if they are not perceived as relevant to radiology—we can still achieve meaningful use."
For radiologists at University Radiology, their forward-thinking RIS vendor had viewed the need for the practice early on to have an EHR, and understood that certain data elements aren't always captured in the RIS and therefore would not be needed for compliance. "Traditional RIS often don't record things such as lab results—key pieces for attesting to meaningful use. If there are lab results in the RIS, they're often scanned, so that doesn't achieve meaningful use compliance, because the data are not captured in a structured way and cannot be mined," Goldszal says. "However, if you aren't thinking outside the box and figure that lab results aren't a component of the radiologist's work, so it won't be included, then you have missed the boat, and the technology will not be certified."
In achieving Stage 1 meaningful use compliance, "it's obvious the government wants us to first learn how to crawl, then to walk, before we can run," he says. Stage 1 is about having data in an electronic and structured format, and the ability to, at some later time, mine the data and perform analytics."
However, some people want to jump right into the deep end with Stage 2 and are missing its point. "Achieving Stage 2 means you have successfully achieved Stage 1," Goldszal says." First, you have to put your data in an electronic, structured format and communicate it in a standardized way. It's that simple."
"With an average of 150 patients coming in daily for mammography tests, 10 minutes extra for each patient encounter would markedly impact our workflow and increase costs without improving quality," Whitfill says.
Penn Medicine plans to attest to meaningful use in 2012, and is using its previously implemented EHR. "The health system is participating with other non-radiology providers giving credence to what we are going to accomplish through meaningful use," Langlotz says.
Because of Southwest Diagnostic Imaging's affiliation with Strategic Radiology, a group of 16 imaging centers, Whitfill says this has allowed its radiologists to coordinate their approach to meaningful use.
At Strategic Radiology today, there is a wide spectrum of approaches to meaningful use from "this is complex; it's difficult to qualify and we need to focus on the other challenges, to the other end of the spectrum of aggressive preparations," Whitfill says. "However, most practices/imaging centers are somewhere in between. We're all watching this very closely."
While radiologists were initially excluded from the Medicare and Medicaid EHR Incentive Program for meaningful use (MU) of a certified EHR, revision to an outpatient services code now allows radiologists to qualify for MU like other specialists.
On April 15, 2010, the Continuing Extension Act (H.R. 4851) redefined what constitutes an eligible professional (EP) and eligible hospital (EH). Previously, the place of service (POS) Code 22, outpatient hospital, was part of an EH status. It is now part of EP. The POS Codes 21 (inpatient hospital) and 23 (emergency room) now represent all EH activities. Therefore, today, unless a physician's practice is more than 90 percent inpatient and emergency room services, he or she is considered an EP.
Through calculations from the Centers for Medicare & Medicaid Services (CMS), this revision represents approximately 84 percent of all physicians, and the American College of Radiology (ACR) estimates that it represents more than 95 percent of all radiologists.
Applying for meaningful use
By using an EHR in a meaningful way, providers recognize the benefits beyond merely a financial incentive, such as reductions in errors, the availability of records and data, reminders and alerts, clinical decision support and e-prescribing/automated prescription refills.With more than $1.5 billion available in federal incentive payments for radiology professionals, approximately 95 percent of all radiologists nationally are qualified for up to $44,000 in meaningful use incentives before 2015. To receive these incentives, radiologists must begin using a certified EHR by next year. If an organization does not comply by 2015, it will be penalized through reduced government reimbursement.
Despite the revision by CMS, one big question remains: If a radiologist must prove meaningful use of an EHR by next year, does that mean he or she needs to purchase an EHR to comply with meaningful use? The answer: If a radiologist can attest to meaningful use of a certified EHR through the provider organization he or she works with, than it can be done there.
CMS said that as of late August, approximately 90,000 eligible physicians, healthcare professionals and hospitals had registered for meaningful use with EHR incentive payments totaling $397,366,554. The Congressional Budget Office estimates that 90 percent of physicians and 70 percent of hospitals will use EHRs by 2020 and benefit from the incentive program.
Keith Dreyer, DO, PhD, vice chair of radiology at Massachusetts General Hospital in Boston, and chair of the IT government relations committee at the ACR has been actively involved in educating his colleagues, the healthcare industry, the Office of National Coordinator of Health IT and legislators about meaningful use and how radiologists can best qualify for incentive payments.
Radiologists and their practices are unique from other specialties, Dreyer says, as they are able to tag MU through their hospital or health system. "Unlike other specialties, radiologists, for the most part, don't purchase the technology they use. Most radiology practice purchases are done by someone other than the radiologist, typically the CMIO or CIO."
Radiologists who practice in a hospital are finding a lack of assistance from the provider. If a hospital determines it cannot provide assistance to the radiologists for whatever the reason, the radiologist needs to move forward with a plan, Dreyer says.
"We need to enlighten CMIOs and CIOs to create technology that is above and beyond the common technologies found in radiology [e.g., PACS, RIS]. If the radiologist needs to add a patient's height and weight, then that needs to be in there to receive the incentive payments," he says. "There is so much misinformation out there because of all of the activities and rulings. You can't change the regulation; however, it is equally important that CMIOs and CIOs respond to the pleas of the radiologists and include them in their hospital's meaningful use attestations whenever possible."
In addition to the assistance that radiologists require, Dreyer says there needs to be additional thought given to extending some of the functionality commonly found in RIS and PACS for radiologists to comply with meaningful use requirements.
The effect of meaningful use on radiology is that RIS and PACS need to evolve into what Dreyer calls, "an EHR solution." What's needed is for the RIS and PACS vendors to establish a modular certification, and build on that.
Get up, get involved
"Everyone needs to play an active role from the vendors who need to make their systems certified to CMIOs and CIOs who need to inform radiologists that they are eligible, even if they are unable to assist them in applying and attesting to meaningful use," Dreyer says.From the perspective of Alberto Goldszal, MBA, PhD, CIO at University Radiology in East Brunswick, N.J., "there is now flexibility regarding EHR implementations for radiology. We have an EHR, and if we comply with the meaningful use metrics—even if they are not perceived as relevant to radiology—we can still achieve meaningful use."
For radiologists at University Radiology, their forward-thinking RIS vendor had viewed the need for the practice early on to have an EHR, and understood that certain data elements aren't always captured in the RIS and therefore would not be needed for compliance. "Traditional RIS often don't record things such as lab results—key pieces for attesting to meaningful use. If there are lab results in the RIS, they're often scanned, so that doesn't achieve meaningful use compliance, because the data are not captured in a structured way and cannot be mined," Goldszal says. "However, if you aren't thinking outside the box and figure that lab results aren't a component of the radiologist's work, so it won't be included, then you have missed the boat, and the technology will not be certified."
In achieving Stage 1 meaningful use compliance, "it's obvious the government wants us to first learn how to crawl, then to walk, before we can run," he says. Stage 1 is about having data in an electronic and structured format, and the ability to, at some later time, mine the data and perform analytics."
However, some people want to jump right into the deep end with Stage 2 and are missing its point. "Achieving Stage 2 means you have successfully achieved Stage 1," Goldszal says." First, you have to put your data in an electronic, structured format and communicate it in a standardized way. It's that simple."
The value of data
University Radiology is collecting more patient information today because it recognizes the value in data. "We ask people if they smoke. Clearly, if they come in for a chest x-ray with symptoms of a cough, then that's a relevant clinical question to be asking," he says. However, if a person comes in for an x-ray of his or her foot that was injured over the weekend playing touch football, why ask about smoking habits? Ultimately, it's about compliance. "It's largely irrelevant to the encounter. Nevertheless, it's information that the government wants and needs to answer epidemiological questions," he says. While Curtis P. Langlotz, MD, PhD, professor of radiology and vice chair for informatics in the department of radiology at Penn Medicine in Philadelphia, sees some incremental value for radiologists to track a patient's smoking history when he or she comes in for an ankle x-ray, it is only "marginal," he says. "I would prefer to see specialty specific criteria. For example, if radiologists are going to spend their time thinking about meaningful use, their time would be much better spent looking at ways IT can improve the quality of care that we deliver as radiologists."| Preparing For Meaningful Use |
These preparation guidelines were adapted from the radiologyMU.org web site. When developing a strategy for meaningful use, it is important to examine financial implications, exclusion opportunities and the overall impact of CMS EHR incentive programs on the imaging practice. Strategies will vary based on practice scenarios however. Listed below are tips to help prepare for meaningful use.
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More data collected
Radiologists at Southwest Diagnostic Imaging in Scottsdale, Ariz., questioned if they could purchase an EHR for the specific radiology requirements, says James Whitfill, MD, CMIO. However, during their evaluation, they discovered that if they were to take their average of 600,000 exams a year and staff had to capture the patient's vital signs and weight for every exam, the reporting process would add an extra 10 minutes to each patient encounter every day."With an average of 150 patients coming in daily for mammography tests, 10 minutes extra for each patient encounter would markedly impact our workflow and increase costs without improving quality," Whitfill says.
Penn Medicine plans to attest to meaningful use in 2012, and is using its previously implemented EHR. "The health system is participating with other non-radiology providers giving credence to what we are going to accomplish through meaningful use," Langlotz says.
Because of Southwest Diagnostic Imaging's affiliation with Strategic Radiology, a group of 16 imaging centers, Whitfill says this has allowed its radiologists to coordinate their approach to meaningful use.
At Strategic Radiology today, there is a wide spectrum of approaches to meaningful use from "this is complex; it's difficult to qualify and we need to focus on the other challenges, to the other end of the spectrum of aggressive preparations," Whitfill says. "However, most practices/imaging centers are somewhere in between. We're all watching this very closely."
More Useful Information
For further information, register (for free) to view “Meaningful Use in Radiology,” a presentation with Arun Krishnaraj, MD, MPH, from Massachusetts General Hospital from the Health Imaging Virtual Conference on Sept. 14th. Keith Dreyer will address meaningful use on Nov. 16. Register here: healthimaging.com/virtualconference2011| Can PQRI Submissions Be Used For Mass Attestation of Meaningful Use? | ||||
In an interview with CMIO, Banas noted that his facility has more than 800 EPs who will have to perform individual manual data entry during their attestation process. During the session, Banas asked if the group practice reporting option for CMS' Physician Quality Reporting Initiative (PQRI), or the existing registry based submission process, might serve as a model to allow groups of providers to attest to meaningful use. Banas envisioned a spreadsheet that a group could fill out on behalf of its providers. "Currently, CMS, through PQRI, will allow providers to submit for current quality reporting measurements in a variety of manners—claims based, registry based and a group reporting option," Banas said. "Would that not meet the same requirement by handling the process in a similar manner for meaningful use attestation? We already submit this registry [e.g., spreadsheet] to CMS, so why can't we do this for meaningful use?" As part of the Social Security Act, CMS created a group practice reporting option for the PQRI system in 2010. Group practices that report data on PQRI measures for a particular reporting period are eligible to earn a PQRI incentive payment equal to a specified percentage of the group practice's estimated Medicare Part B physician fee schedule allowed charges for covered professional services. For registry reporting, EPs must use an approved registry. Then the registry, with its captured and stored information, is used for submitting measurement information to CMS and calculating performance rates on behalf of the EPs. Providers can submit data to the registry at any time during a reporting period or up to one month after. Reports can be submitted to CMS in batches or retrospectively, as they come in. A similar process for meaningful use would allow an EMR to populate a registry or a group representative, such as a CMIO, to populate a spreadsheet with data on behalf of the group and apply for meaningful use through a single channel, rather than completing the estimated 15 required screen-flips to attest to meaningful use. "For a health system with 800 clinicians and providers, a batch approach would leverage the EMR reporting for the entire group, rather than making us perform non value-added manual data entry steps," he says. Banas' peers have commented that his logic was spot-on, "and they hope that CMS hears this as a possible solution." During the symposium, Anthony responded that Medicare currently has a pilot program being reviewed that would allow EPs to submit their quality measures for meaningful use in the same manner as PQRI. Stay tuned. |
