SIIM: Dreyer busts meaningful use myths for rads
 |
The myths: Busted
Many MU myths that have been perpetuated over the last 18 months and all are false, stated Dreyer, including:
- Radiologists are not included in MU.
- Radiologists were singled out in MU.
- RIS/PACS is excluded in MU.
- RIS/PACS is included in MU.
- A specific requirement has been included in stage 2.
- A specific requirement has been excluded in stage 2.
- It is impossible to achieve.
- Radiologists don’t have to worry about penalties.
- If physicians wait, MU will go away.
However, Dreyer shared a few fundamental truths about MU. “It is not easy. Meaningful use is different for every practice. Vendors are learning about meaningful use at the same time as physicians.”
Alphabet soup of fundamentals
MU was born in February 2009 with the passage of the American Recovery and Reinvestment Act and the HITECH ACT, which allocated $20 billion to MU. At that point, radiologists may have been excluded, but the situation changed in April 2010 with the passage of the Continuing Extension Act. The update removed outpatient from the eligible hospital category, essentially qualifying about 90 percent of radiologists as eligible providers.
A pair of federal agencies handles MU. The Centers for Medicare & Medicaid Services (CMS) regulates payments and Office of the National Coordinator for Health IT (ONC) regulates technology.
In July 2010, CMS announced stage 1 measures and exclusions with 15 core measures and 10 menu set measures. Most measures have exclusion criteria, so if the measure doesn’t apply to a professional, he or she may be excluded and several are optional. In addition, eligible providers also must report on six of 44 clinical quality measures.
Dreyer advised radiologists to review compliance and exclusion thresholds and to remember that all thresholds will increase in stages 2 and 3.
However, physicians don’t need to physically track most measures. “Most measures can be done by a paraprofessional or automated into the system,” shared Dreyer.
The magic number for MU is $44,000. Physicians who start reporting in 2011 or 2012 may earn the maximum incentive of $44,000 by 2015. Although radiologists can earn the maximum by collecting data beginning as late as Oct. 3, 2012, they need to start thinking about MU now, urged Dreyer.
The vendor connection
One reality about MU? “You will be relying a lot on vendors,” shared Dreyer. “Most EHR vendors were well-prepared for this process. That is not the case for radiology IT. Some vendors have complete certification. Others are partially certified.” The exceptions are RIS and practice management systems, said Dreyer, as many are already certified.
In fact, RIS can be used to meet most measures that apply to radiology. Others are portal or PACS functions, and clinical decision support is the final product component. The upshot? “You need to discuss meaningful use plans with your vendor.”
The product certification process takes approximately six to 18 months, and vendors can opt for complete certification for all 33 criteria or a modular certification for single or multiple criteria. If a practice employs modular technology, it needs to combine multiple modular certified products.
Another important point, continued Dreyer, is that the current ONC regulations state that a provider needs to possess all certification criteria even if they don’t use them to meet specific measures. That means a radiology practice, which is likely exempt from immunization measures, still has to buy technology to meet immunization measures. “This may change in future regulations,” noted Dreyer.
The 10-step approach to MU
Dreyer boiled the MU process to a 10 steps.
1. Understand the fundamentals of MU.
2. Determine eligibility and financial impact.
3. Determine MU measure requirements and complete an exemption analysis.
4. Meet with practice stakeholders including IT and medical staff.
5. Meet with radiology IT vendors.
6. Plan MU technological and operational strategies. “Consider consultative advice and aim for minimum radiologist workflow burden,” Dreyer advised.
7. If needed, acquire and implement MU technology.
8. Register online with CMS.
9. Monitor compliance regularly.
10. Attest online with CMS.
MU ahead
With many radiologists still confused or misinformed about MU, Dreyer shared the pros and cons of pursuing MU. The integration of radiology into MU is challenging; however, not participating could have a negative financial impact and perception issues. The current one-size-fits-all approach is difficult for radiologists to navigate, and MU measures are not necessarily clinically relevant for radiologists.
Dreyer offered a few positive reminders and updates. Ultimately, radiologists are eligible for incentives and penalties. Although certified radiology health IT solutions are limited, the situation is improving, with most vendors working on a pathway.
On June 8, the working group of ONC will submit recommendations for stage 2. Two months later, the group will send a second group of recommendations that addresses specialty issues including medical imaging. Stage 2 should be finalized by the first quarter of 2012.
Dreyer concluded with a few recommendations for radiology advocacy. Specifically, he advised the audience to:
- Promote the specificity of measures and exclusions for radiologists;
- Request that CMS remove the requirement for possession of all certification criteria;
- Emphasize an expanded definition of radiology results that includes images; and
- Promote the use of American College of Radiology appropriateness criteria for imaging clinical decision support.