Looking For Imaging in Stage 2 of Meaningful Use

Industry comments on the draft criteria for Stage 2 of the meaningful use program are in. Now specialty leaders and practices are waiting with bated breath see if Stage 2 recommendations offer any clarity on how radiologists will be required to implement electronic health record systems (EHRs).

As it stands now, specialty leaders aren’t holding out much hope the Stage 2 guidelines - which have no mention of imaging - will differ much from the uniform approach taken with Stage 1.

“The overall view is that the one-size-fits-all tactic will largely continue to be the case,” said Michael Peters, director of legislative and regulatory affairs for the American College of Radiology. “We’ve asked for specialty-specific paths because it’s the right thing to do, but we don’t anticipate that the federal agencies will have the time to noodle around and create pathways for all specialties.”

Without knowing the final recommendations from CMS, it’s impossible for radiology practices to effectively prepare for Stage 2 implementation, he said. Proposed rules are expected by late 2011 or early 2012.

Currently, CMS is proposing flexible criteria for specialties, such as radiology and orthopedics, that would exclude practitioners from some meaningful use guidelines. For instance, if you write fewer than 100 e-prescriptions during the EHR reporting period, you’re exempt from following the meaningful use protocol. Fortunately, taking advantage of the flexible criteria won’t disqualify you from receiving the $44,000 incentive payments for proper EHR implementation by 2012, Peters said.

In addition to the CMS guidelines, you’re also facing recommendations from the Office of the National Coordinator for Health Information Technology (ONC) that require you to at least maintain certain EHR technologies even if you’re not using them. With both agencies not necessarily being in lock-step, it’s understandable if you’re confused.

ACR recommends that, at present, you comply with ONC regulations by implementing a certified EHR system, such as traditional electronic medical records software or EHR modules. For further clarity, the ACR has requested that diagnostic images and imaging data be retrievable through the EHR technology you choose, and that you only be required to implement the technologies that you use routinely, such as RIS/PACS. Doing so would give radiology a more individualized approach to meaningful use, said Keith J. Dreyer, DO, PhD, chair of the ACR Information Technology and Informatics Committee-Government Relations Subcommittee.

“What makes sense in primary care does not always make sense in specialties,” he said. “It would be more beneficial from a care coordination perspective if imaging professionals were asked to make scheduling options available, receive electronic orders, develop structured reports in a timely fashion, provide Web-based access to images and reports and adhere to standards of image archival, access and display set forth by national organizations.”

Taking those steps, he said, would benefit both providers and patients.

Peters also recommends keeping an eye out to see if CMS agrees with ACR’s suggestion to increase the number of exclusions that are based on the scope of practice, rather than patient demographics.