It was the radiology community’s version of the shot heard ‘round the world: in April 2010, the Continuing Extension Act of 2010 revised the Health Information Technology for Economic and Clinical Health (HITECH) Act’s definition of a hospital-based eligible professional to include hospital-based physicians practicing in outpatient settings, thereby rendering more than 90% of radiologists eligible for the meaningful-use program. Previously, imaging providers had believed that they would be exempted from the maze of attestation, incentives, and penalties prescribed by the HITECH Act, but suddenly, they (and their information systems) were in the loop.
Radiologists have always been early adopters, when it comes to IT, but the stage 1 meaningful-use requirements were, predictably, written with a broader audience in mind. Therefore, they require the use of either an electronic health record (EHR) or a product certified by the Office of the National Coordinator (ONC) as a modular EHR—for instance, a RIS with additional capabilities worked into its millions of lines of code—for information aggregation and attestation.
Keith Dreyer, DO, PhD, vice chair of radiology computing and information sciences at Massachusetts General Hospital in Boston, says, “We’re hoping that the stage 2 guidelines will be more attuned to radiologists. For many groups, there’s just too much money on the table to ignore this.”
With stage 2 requirements pending, Michael Peters, director of legislative and regulatory affairs for the ACR®, says that radiologists should brace themselves for more of the same. “I’d expect to see more inclusion of specialists through exclusions, but overall, more continuation of the one-size-fits-all approach,” he explains, adding that the ACR has been pushing for more in Washington. “Everyone understands that CMS and ONC regulators cannot conceivably create unique participation and technology requirements for each and every medical specialty, but there has to be a middle ground between that paradigm and the current approach,” he says.
The Lay of the Land
In June 2011, the ONC working group tasked with developing the requirements for the meaningful-use program indicated to radiology stakeholders working on Capitol Hill—Dreyer and the ACR among them—that it was in the process of carving out separate recommendations for medical specialties, and hinted that these recommendations might be rolled out as early as stage 2.
Peters, however, is not optimistic that the changes will be seen so soon. “I and my counterparts in the other specialty societies have been trying to make sure this stays on their radar, but those recommendations may not be available until the stage 2 proposed rules are out the door and going through the necessary review processes prior to publication for comment,” Peters says.
In the meantime, attestation for stage 1, a 90-day process of collecting and reporting patient information to CMS, can begin in either 2011 or 2012 for eligible providers hoping to capitalize fully on the incentives offered by the HITECH Act. Totaling $44,000 per eligible provider for those who follow the agency’s timeline and begin with stage 1 before the end of 2012, the incentives are tempting—and, of course, they will be replaced with penalties in later years.
Steven Fischer, CIO for the Center for Diagnostic Imaging (CDI), Minneapolis, Minnesota, says, “We did a financial assessment, and it makes sense for us to pursue this—not so much for the incentives, but because of the hammer coming down in 2015. The incentives do add up, however; it’s a pretty nice chunk of change, even after expenses.”
Because the stage 1 requirements—and, if all indications prove true, the forthcoming requirements for stage 2—are geared toward physicians in general (not specific specialties), attestation can only be achieved using an EHR or an ONC-certified modular EHR. RIS vendors are scrambling to update their software to attain this certification, although the process is, obviously, a cumbersome one. At the June 2011 annual meeting of the Society for Imaging Informatics in Medicine in Washington, DC, vendors shared their progress on attaining the coveted certification, but for the most part, there was little to celebrate yet.
“What I am telling people right now is get to your vendors and let them know what you need,” Dreyer says. “There’s not enough pull coming from radiologists yet, and as a result, the response from the vendor community has