Federal incentive programs have been underway for just over a year to encourage adoption of electronic health records (EHR), but how this relates to radiology is not much clearer now than at the programs’ start. Part of the Health Information Technology for Economic and Clinical Health (HITECH) Act, the programs offer Medicare/Medicaid incentives to eligible professionals and eligible hospitals for adopting certified EHR technology and utilizing that technology in a meaningful way. The idea is both to stimulate the economic side of the industry and to bring it into the 21st century technologically. In order for hospitals and healthcare professionals to be considered compliant, they must demonstrate “meaningful use” of the technology in their daily practice.
The difficult part of the process has been defining “meaningful use.” Final Stage 1 requirements were released in June 2010, but did not include any radiology-specific information.
“In the radiology sector, the overwhelming majority of people are very much in the education phase. If I talk to 100 people, for 80 of them, it’s about the basics of meaningful use and what it means for radiology,” said Paul Merrild, senior vice president of solutions management at Merge Healthcare.
One of the elements in particular making life difficult for radiologists is that Stage I requirements skew heavily toward primary care physicians. Finding where radiology fits into the big picture is giving many radiologists pause.
“Some people are getting hung up on the distinction of whether or not they meet the definition of an eligible professional. Others are asking what they will need in their technology, especially from a reporting point-of-view,” Merrild said.
He explained the rules themselves, issued by the Centers for Medicare and Medicaid Services (CMS), make the first issue crystal clear: any radiologist who receives more than 10 percent of his or her CMS revenue from sources of business beyond the hospital inpatient and emergency departments qualifies for the EHR incentive program. Using those parameters, the vast majority of radiologists qualify.
Just because most people can qualify, however, doesn’t necessarily mean they want to. The results of a survey conducted by information management/storage company Iron Mountain, published in July 2011, reveal that many hospitals are currently in a “hybrid” stage between paper and pixel. According to the survey of 201 health information professionals, 70 percent expect to claim EHR compliance; however, 78 percent also say they plan to continue using paper records for at least another five years.
That five-year timeline may be costly in the end. CMS expects to implement Stage 2 in 2013 and 2014, though discussion continues about extending these deadlines. Starting in 2015, the agency will cease incentive payments and begin penalizing non-compliers by reducing Medicare and Medicaid reimbursement.
Lighting the Path
Merge Healthcare is working toward EHR certification for its technology. The company has been working with the Drummond Group, an Office of the National Coordinator authorized testing and certification body (ONC-ATCB), to have its Merge Radiology Information System (RIS) 7.0 and OrthoEMR 4.0 software certified. Merrild said the company hopes to have the process completed by the end of the third quarter of 2011.
The technology arena is just one way that the company is helping its clients toward meaningful use. In fact, it’s not even the biggest part of the mission, as he sees it. “It’s really all about education for now,” he explained. “We are working to educate our customers; it’s a lot about posing questions to CMS and getting clarifications on the specialty for radiology.”
The company also is creating what Merrild calls a “cookbook,” a 100-page document that essentially is a meaningful use manual. “We want to hand that off to our customers as a component of their overall meaningful use program to help them navigate this,” he said, “because it’s pretty darn confusing.”
The Center for Diagnostic Imaging (CDI) in Minneapolis, Minn., is one of those providers making strides toward meaningful use of EHR technology. Its focus is based upon its radiologists being outpatient providers, as opposed to hospital-based or -employed radiologists.
According to Linda Bagley, vice president of business systems and operations support at CDI, they are satisfied with how things are moving so far. “It’s a very tight schedule for us here at CDI,” she said. “We’re still trying to get a certified system up and going so that we can actually start our 90-day period,” referring to the Oct. 3 deadline for eligible professionals to begin their 90-day reporting period for calendar year 2011.
Instead of waiting for Merge’s release of the meaningful use-centric Merge RIS 7.0, CDI chose to work with Merge to bring its existing RIS up to the certification requirements. This includes the bundling of a feature set to support e-prescribing, as well as other enhancements to the system.
Bagley points to the value of its efforts. “We have radiologists who do therapeutic injections here and we give some patients prescriptions,” Bagley said. “Being able to electronically prescribe will benefit our patients and our radiologists.”
For any group or professional going through the meaningful use process, Bagley said careful examination and a team approach are necessities. “I think the biggest thing is really just to sit down as a core team and look at the menu sets that are out there and actually look at…each one of those and determine how to align the criteria with your core business.”
Looking to the Future
Of course, as eligible professionals and hospitals are trying to grasp the Stage 1 requirements, they do so with the knowledge that Stage 2 measures are not that far off. This will require them to prepare for additional guidelines.
Exactly when that will happen is unknown. The initial draft of Stage 2 is currently in the public comment period, after which CMS and lawmakers will make adjustments based on the public feedback. Merrild said how Stage 2 will actually turn out is anyone’s guess at this point.
“From a product point-of-view, as soon as we understand what it’s going to be, we will develop around that and do our best to meet the Stage 2 guidelines,” he said. “We’re actively paying attention to that legislation and we’re trying to influence it to be more relevant for the practice of radiology.”
Further muddying the picture is the current push by providers to move the Stage 2 timetable back. Merrild believes it is because they simply are not ready to deal with more changes so quickly.
“They’re overwhelmed with the implementation of their certified EHR; they’re overwhelmed with the prospect of ICD 10 [a new coding system for the entire healthcare industry] coming in 2013, and then they’re overwhelmed with…having a subsequent layer of meaningful use thrown on top of them,” he said.
Luckily for providers, the Health IT Policy Committee (HITPC) — an industry group working with CMS on meaningful use — has been listening. In a June 2011 letter to Farzad Mostashari, the national coordinator for health IT, the committee recommended eligible professionals and hospitals that began reporting in 2011 should get an extension until 2014 to start Stage 2 reporting. Providers that start Stage 1 in 2012 will still have to report on Stage 2 in 2014.
HITPC also suggested changes to the measures themselves, making some of them more accessible to radiology in particular. For example, one core measure for eligible professionals in Stage 1 is the use of computerized physician order entry (CPOE) for medication. The accompanying clinical quality measure (CQM) says that compliance is equal to inputting more than 30 percent of total medication orders via CPOE. For Stage 2, in addition to a threshold increase to 60 percent or greater, eligible professionals must include at least one radiology order during the reporting period. (See sidebar for more details about the HITPC’s recommendations)
Ultimately, whatever the outcome of Stage 1, people like Merrild and Bagley are hopeful that Stage 2 will bring benefits for patient and physician alike.
“We do view the importance of the image in the medical record to be critical,” Merrild said, “and that’s one of the things that we’re trying to make clear to CMS as it decides, and ONC decides, what actually makes it into Stage 2.”