Ready, Set—Attest

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When Keith Dreyer, DO, PhD, speaks to an audience of radiologists on meaningful use (something he does quite often, these days), he always asks for a show of hands to determine who is doing what with regard to demonstrating meaningful use of IT. Dreyer, vice chair of radiology computing and information sciences at Massachusetts General Hospital in Boston, reports that despite their eligibility for the incentives—and exposure to penalties in 2015—a scant few are in the process of attesting to meaningful use of health IT in 2011.

In his keynote presentation, “Meaningful Use for Radiologists: A 10-step Guide,” given at the First Annual ACR® Imaging Informatics Summit on November 3, 2011, in Washington, DC, Dreyer says, “The fuse is still burning. It is a year before you will lose some of the incentives.” Dreyer urges every practice to follow this 10-step strategy, to determine whether it should attempt demonstration of meaningful use and, if viable, to attest to it.

First, consider the specific requirements of the program. To make a decision about whether or not your practice should participate, you must understand the fundamentals of meaningful use.

Second, determine your eligibility. You are probably eligible, but do the math, Dreyer urges. Look at your group’s billing history to determine whether you are at the 90% threshold or below it (to be excluded, 90% of your work must come from inpatients or the emergency department).

The incentives accrue per physician; how many radiologists do you have who fall within this threshold? What are the pluses (incentive dollars, as well as potential benefits of further IT investments) and the minuses (penalties begin in 2015)? Dreyer recommends using the eligibility calculator at www.healthmu.org.

Third, determine the number of measurement requirements that you must meet. Work through the exclusions for the MU objectives to find out what you have to do, and the ones from which you can exclude yourself. Dreyer recommends getting general counsel involved on the exclusions, but some of the measures that radiologists can potentially build an exclusion case for include those pertaining to performing immunizations and transitions of care, collecting syndromic information, office visits, and prescribing medications (contrast agents are considered supplies, not medications).

At this point in the process, a practice should have determined whether it will proceed or not with demonstrating the meaningful use of health IT. If so, it proceeds through the next seven steps.

Fourth, meet with practice stakeholders. These include your department or practice IT staff, your hospital IT staff or CIO, your CMO, and your medical group (if you are part of a multispecialty medical group). Find out whether there is something you can do collectively and what kind of support you can expect from the hospital, if any. Fifth, meet with your radiology vendors to understand their plans for the products relevant to demonstrating stage 1 meaningful use: RIS, reporting, and practice management.

Sixth, plan and execute your technology purchases and operational strategy. Unless your RIS is already certified as a complete electronic health record (EHR)—and some have been—you may want to consider bringing in a consultant or appointing a staff person to explore this more deeply and make some decisions. These will be much like what happens in a PACS- or RIS-selection process. The goal is to minimize the radiologists’ workflow burden.

Seventh, determine whether you need to acquire additional meaningful-use technology—or upgrades to implement meaningful use—through discussions with your vendors. One thing that a practice will need is a dashboard view that will enable all radiologists (or someone acting on their behalf) to assess whether they are meeting their thresholds for each measure on an ongoing basis, so that if they are not, they can make adjustments.

Complete certified products are dashboards, Dreyer says, so vendors must demonstrate in the certification process that they can make that functionality available. Modular certified RIS products will need to be interfaced with the complete EHR, however, and additional software and technology could be required to provide that dashboard view for radiologists.

Eighth, comply. Register (at www.cms.gov/EHRIncentivePrograms/20_RegistrationandAttestation.asp), as 90,000 physicians already have, using your national provider number. Ninth, monitor your compliance