The Plot Thickens on Meaningful Use for Radiology

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Keith Dreyer, DO, PhDThere is bad news and good news for radiology, when it comes to meeting meaningful-use requirements, according to Keith Dreyer, DO, PhD, vice chair of radiology computing and information sciences at Massachusetts General Hospital (MGH) in Boston. In the Dwyer Lecture, “Meaningful Use in Medical Imaging: New Technologies for US Healthcare Reform,” which he presented at the 2011 meeting of the Society for Imaging Informatics in Medicine on June 3 in Washington, DC, Dreyer began by debunking certain meaningful-use myths. These myths were that radiologists have somehow been singled out by the regulations, that the stage 2 requirements have already been released, and—most important—that there’s a chance that radiology will not have to deal with meaningful use at all. “That’s not the case,” Dreyer says. “This is not going to go away. We need to get more and more involved, rather than burying our heads in the sand.” The misconception that radiology might somehow be exempted from the requirements dates back to the original Health Information Technology for Economic and Clinical Health Act, Dreyer says, which appeared to exclude the specialty. In April 2010, however, the Continuing Extension Act of 2010 mandated a change to the requirements that brought radiology back into the fold. By revising the original definition of hospital-based eligible professional to include hospital-based physicians practicing in outpatient settings, the legislation rendered over 90% of radiologists eligible for meaningful-use certification. “It looked like this wasn’t going to involve us,” Dreyer notes, “until the second law was passed.” Now that the vast majority of radiologists are clearly eligible, one area of confusion among both hospital-based radiologists and their colleagues is whether radiologists are eligible professionals or part of eligible hospitals. Dreyer says that the former is almost uniformly the case. “You’re part of an eligible hospital if 90% or more of your practice is in an inpatient hospital or emergency department. What is the chance of anyone in your group having 90% of interpretations coming from inpatient or emergency-department visits?” he asks. Radiologists should start taking pains now, he urges, to explain this to those within their hospitals whose support they might need as they move forward. “Help your hospital CIOs understand that you are eligible professionals,” he advises. Another contentious subject is that of how radiologists should prepare to meet the stage 1 requirements laid out by CMS. Dreyer explains that according to the Office of the National Coordinator (ONC), modular certification is an option for vendors—meaning that applications like RIS can attain modular certification—but there is no corresponding modular option for radiology and other specialties. “You can exclude yourself from some of the requirements and opt out of others,” he says, “but you still have to possess the technology to do all of the other things (even if you don’t use it) to meet your meaningful-use measures. I have to have the ability to do immunizations, even though I never will.” Steps to Radiology Meaningful Use Since there is no way out of or around meeting the requirements, Dreyer outlines four steps for radiology practices to take to achieve meaningful use. Step 1 is consideration. Practices should make sure that they understand the fundamentals of meaningful use, he says, and should determine both their eligibility and the potential financial impact of the program. Tools available free at www.radiologymu.org can assist with both analyses. Step 2 is preparation. Groups should assemble their stakeholders and initiate planning conversations with the IT staffs of their groups and/or hospital. They should also meet with their radiology IT vendors to assess what their plans are for meaningful-use certification. Step 3 is execution. The most important goal, at this phase, is maintaining radiologists’ productivity, Dreyer stresses. “If needed, consider acquiring additional technology,” he says, “and you need a dashboard view of measure compliance to make sure you’re hitting those thresholds before you attest.” Step 4 is compliance. Registration for the program can be completed online at www.cms.gov/EHRIncentivePrograms/20_RegistrationandAttestation.asp, and large practices are now permitted to sign up via single administrator. Dreyer describes online attestation as pretty straightforward, and a sample attestation calculator is provided at www.cms.gov/apps/ehr. Documentation of the process must be maintained for six years. The Upside Though the requirements are burdensome in the short term, the news isn’t all bad, Dreyer says. To begin with, at a maximum of $44,000 per eligible professional through 2015, the incentive bonuses offered by CMS have the potential to add up quickly. In a seven-year financial go/no–go analysis performed by MGH, the hospital discovered that its eligible hospital incentives would add up to $42 million, while its incentives for eligible professionals, including radiologists, added up to $58 million. “That’s $100 million in seven years for a typical large academic medical center,” Dreyer says. Special provisions for radiology and other specialty areas of medicine might also be in the offing, he adds. Just two days before his talk, the ONC meaningful-use working group indicated that it would submit a separate set of recommendations for specialists, with the understanding that the one-size-fits-all approach to the eligible-professional side of the regulations is not working. “They said they will send another recommendation that includes specialty issues—and specifically, medical imaging—in approximately two months,” he says. “It’s very encouraging that they’re seeing that they have to address medical imaging to have a really complete electronic health record (EHR) meaningful-use solution.” Dreyer, who recently testified to the working group, hopes to see the ONC requirement for possession of all certification criteria removed for radiologists, and he wants the definition of radiology results expanded to include images, as a move toward promoting image sharing and distribution via EHR. In the meantime, he calls for radiology groups to see the meaningful-use program as an opportunity, rather than a burden. “You need to be thinking constantly about what you need to do to make your practice better, because that’s what the federal government is telling us to do,” Dreyer says. “There’s going to be more and more pressure coming from the government to us through accountable-care organizations, meaningful use, and more, so it’s in your best interest to understand this.”