Meaningful use: The government's billion dollar gift to radiologists

“Meaningful use” is on everyone’s mind and sure to be a predominant topic for years to come. Despite its significance, many healthcare professionals and technology providers are still unclear as to who is eligible for the federal government’s incentive programs and what needs to be done to certify technology and achieve meaningful use.

Did you know that more than 84% of all physicians and 90% of all radiologists are considered eligible professionals and qualify for meaningful use incentives? With $44,000 per radiologist up for grabs, more than $1 billion could be available for the diagnostic imaging community. That’s the carrot.

Of equal importance is the potential penalty impact if eligible radiology professionals do not comply with meaningful use criteria by 2015. Hundreds of millions of dollars will be at risk every year, and that could easily reach billions as private payers begin to adopt guidelines that mirror federal policy. And that’s the stick.

This article will take a look at the progress of healthcare reform, eligibility and certification requirements, Stage 1 meaningful use objectives as they relate to the field of medical imaging, new technologies that will assist with meaningful use compliance, getting ready for radiology meaningful use, and what to expect in the years ahead.

RSNA courses delve into meaningful use details The RSNA has added courses for IT vendors and radiologists to more fully explore how they can use information technology to improve patient care and thus qualify for meaningful use payments.
• Sunday meaningful use course for vendors. Meaningful use for radiology IT vendors: What your customers will demand, and your competition will provide. Sunday, 2:30-3:30pm in room S103AB.
• Monday meaningful use course for radiologists. Adding millions of dollars to your practice through meaningful use. Monday, 3:30-4:30pm in room S402AB.

PROCESS AND PROGRESS

The goal of meaningful use is to demonstrate the use of IT in medicine to enhance quality, improve patient safety, decrease costs, and demonstrate improved outcomes. With a broad core of objectives and meaningful use definitions that are the same for all providers, the prefinal program rules lacked specificity and flexibility for participation by most medical specialties, including diagnostic imaging. However, a comment period earlier this year provided an opportunity for the American College of Radiology, American Board of Radiology, RSNA, and Society of Imaging Informatics in Medicine to work on behalf of the imaging community and urge CMS to define meaningful use criteria in such a way that it would be reasonably achievable by all eligible radiologists. These organizations also offered specific ways in which CMS could improve the final rule to ensure domain-specific relevance.

As a result of this feedback and comments from other sectors of the healthcare community, CMS relaxed the first phase of meaningful use by creating a set of measurement objectives with flexibility to allow for participation by medical specialties.

ELIGIBILITY, CERTIFICATION REQUIREMENTS

In July 2010 the final rule on meaningful use was released, along with a new definition to determine eligibility classification. Eligible hospital (EH) and eligible professional (EP) assignments are based on a series of CMS place-of-service codes. A shift of code 22 (outpatient hospital) from EH to EP resulted in the majority of radiology professionals qualifying as EPs under the Medicare electronic health record (EHR) incentive program. Personal eligibility can be determined by a radiology professional’s patient mix and imaging practice scenario (See Table).

Once eligibility is determined but before incentive payments can be made, all EPs will need to have a national provider identifier; enroll in the CMS Provider Enrollment, Chain, and Ownership System; and have an active account in the National Plan and Provider Enumeration System. Details about these requirements can be found on the CMS website.

EPs will also be required to use certified EHR technology. This means that your imaging practice will have to use existing IT solutions that are certified for meaningful use or implement additional certified technology modules to satisfy all meaningful use measurement objectives.

Healthcare IT software vendors will also play a critical role in meaningful use. Technology providers will need to have their solutions certified and can apply for certification with organizations that are authorized to certify EHR products for eligibility. In late August, the U.S. Department of Health and Human Services’ Office of National Coordinator for Health IT announced the first two organizations authorized to certify technology: the Certification Commission for Health IT and the Drummond Group. These are responsible for certifying that a technology is capable of supporting EPs and hospitals in meeting meaningful use goals and objectives.

To receive the full $44,000 incentive payment, paid in single annual installments, EPs must begin to “meaningfully use” certified EHR technology by 2012. For those EPs who do not demonstrate meaningful use by 2015, there will be reimbursement reductions that have the potential to increase annually.

RADIOLOGY MEANINGFUL USE TODAY

Capturing electronic health information and using those data to track and communicate clinical conditions is the predominant focus of Stage 1 meaningful use. This first phase of meaningful use includes measures that are specific to EHs and EPs. Radiology EPs have a total of 15 core set objectives, 10 menu set objectives, and 44 clinical quality measures. Each set has specific objectives that may be excluded. But all EPs are still required to use certified EHR technology that is capable of measuring all 25 MU objectives, even those a provider chooses to exclude.

As discussed earlier, CMS has relaxed the requirements for 2011 and 2012 in response to public comments. An outline of the final measures is below.

15 Core Set Measures. The core set includes five measures eligible for exclusion. For radiology EPs, three of the measures may be excluded based on practice type and patient population. Of the remaining objectives, eight may be achievable with your current IT investments while the remaining measures will likely require your department to implement new, certified technology modules.

10 Menu Set Measures. The menu set allows EPs to select five of 10 measures to report. For radiology EPs, three measures may be excluded based on practice type and patient population. Based on menu set requirements, radiology EPs would be responsible for reporting two of seven menu set measures. Like the core set measures, menu set measures will likely require implementation of new certified technology in order to comply with meaningful use objectives.

44 Clinical Quality Measures. The CQM includes 44 measures of which EPs are required to report on six (three core and three noncore).

ONE PROVIDER'S PERSPECTIVE

While many of the requirements for meaningful use may be satisfied by your existing IT investments, such as RIS, PACS, and voice recognition, some of the remaining objectives will require further product development from radiology solution manufacturers or the purchase of new certified technology modules by your imaging practice. There are solutions, such as clinical decision support applications and image sharing technology, that, once certified, will have the potential to satisfy meaningful use objectives that are most likely not achievable with your existing technology investments.

At Massachusetts General Hospital we have identified meaningful use objectives that our legacy systems do not address. These objectives and measures include:

• Implement one clinical decision support rule;

• Provide patients access to their health information via an electronic portal;

• Electronically exchange key clinical information among patient-authorized providers;

• Generate lists of patients by specific conditions; and

• Report ambulatory clinical quality measures to CMS and the states.

IMAGE SHARING

Our organization is in the process of identifying core and menu set objectives that our current radiology IT investments satisfy. As a result of this self-evaluation exercise, our group has noted gaps in existing solutions and identified other technology that must be developed or implemented to comply with radiology meaningful use measurement criteria.

We recently implemented an image sharing platform (lifeIMAGE, Newton, MA) to assist our organization in achieving care coordination goals. While our initial objectives included the elimination of CD/DVDs, enterprise and cross-provider sharing, and online access to imaging data for patients, we recognized an opportunity to utilize this new investment to satisfying meaningful use objectives that would otherwise not have been measurable with the technology that exists in our department today.

After certification, the lifeIMAGE solution will allow our radiology group to meet some of the aforementioned meaningful use objectives not currently achievable with most RIS or PACS systems. These objectives include providing patients access to their health information via an electronic portal, electronically exchanging key clinical information among patient-authorized providers, and generating lists of patients by specific conditions.

When evaluating new technology investments such as an image-sharing platform, many factors should be considered, including security, access control, HIPAA compliance, identity management, backup options, and EHR/PHR integrations. Also, be sure to discuss meaningful use certification plans with technology providers prior to investing in new solutions so that your organization may benefit from the deployment of these technologies and utilize them as modular components of your meaningful use compliance plan.

GETTING READY

As radiology meaningful use gains momentum, diagnostic imaging groups will need to prepare for the impending change. Below are some tips for your organization as your radiologists prepare to become meaningful users.

• Review the imaging IT investments and solutions you have in place today;

• Determine what meaningful use objectives can be measured with your existing IT infrastructure;

• Evaluate new technology to satisfy meaningful use objectives your existing solutions do not capture and measure;

• Discuss certification plans with your existing technology providers as part of your new technology evaluation process; and

• Educate yourself by engaging in discussions with colleagues and visiting informative websites, such as radiologyMU.org, that are dedicated to the topic of meaningful use for the field of medical imaging.

WHAT TO EXPECT

There is considerable pressure for all physicians, including specialists such as radiologists, to become meaningful users. Determining your eligibility, evaluating certified technology, and reviewing your imaging practice’s IT infrastructure are necessary components of successful participation in meaningful use incentive programs.

Meaningful use is moving rapidly, but with a clear trajectory. Stage 1 meaningful use focuses on electronic data capture, while Stages 2 and 3 expand on this foundation by promoting quality, structured information exchange, and safety, efficiency, and population health improvements.

One thing is clear: the practice of medicine is changing and EHR technology will undoubtedly provide medical providers with more information than ever before. As healthcare professionals, we will be able to capture more information about patients, share that information with colleagues at other facilities, and improve the quality of individual patients’ care while monitoring and reporting data to federal committees to achieve health improvements for the population as a whole.