For radiology practices and imaging centers still debating the pros and cons of Stage 2 meaningful use (MU), the calendar looms larger with each passing day. Stage 2 MU now begins in less than a year, and while eligible providers have until 2016 to attest to Stage 2, everyone must go through two years of Stage 1 attestation before progressing to the next stage. Arcadia Radiology Medical Group (ARMG) and California Medical Business Services went through the Stage 1 MU process early, in order to prepare for Stage 2.
This article shares what was learned, and will hopefully nudge others to follow in our footsteps. The benefits are significant: greater incentive payments, better sharing of information within referral communities, and more efficient patient care, among others.
By attesting for Stage 1 early instead of waiting for the final deadline, radiology practices and imaging centers will be set up to be successful for Stage 2. Teams will already be comfortable collecting data, they’ll have made necessary workflow adjustments, and will have started the engagement process with the rest of the community.
Why Radiologists Should Pay Attention
As background, the MU program is part of the 2009 HITECH Act, with a goal of incentivizing electronic health record (EHR) adoption among healthcare providers. Eligible professionals (EPs), eligible hospitals and critical access hospitals (CAHs) that demonstrate meaningful use of certified EHR technology (CEHRT) can receive incentive payments for the use of CEHRT and, more importantly, avoid penalties that begin in 2015.
This program has been under way for several years. As of December 2012, more than 350,000 Medicare and Medicaid eligible professionals have received funding.1 However, the message to radiologists about if and when they should deploy CEHRT and attest has been somewhat mixed. Early messages encouraged participation in MU to better engage with the referring community and receive incentive bonuses. But they conflicted with other messages, including that MU didn’t apply to radiology and the whole process was just too difficult. Stage 2 MU changes all of that. Imaging has a more comprehensive role in the Stage 2 rules. New metrics are available through CEHRT, including a mandate that computerized provider order entry (CPOE) must be used for 30 percent of radiology orders — the same measure mandates that CPOE must be used for >60 percent of medication orders and 30 percent of lab orders — and a new optional measure that more than 10 percent of all tests that result in one or more images ordered by the eligible provider (EP) during the reporting period.
Once radiology practices and imaging centers agree to be part of the MU program, the best course of action is for EPs to go through Stage 1. Under the Medicare program, practices that start attesting in 2013 can receive up to $39,000 per EP over the next four years.
Arcadia Radiology Medical Group and The Hill Medical Corp. began working toward MU compliance early so they could go through the process at the same time as their referring physicians and have each radiology group learn from and support the other. With the end goal to electronically connect clinicians to other clinicians, it made sense to work through the process together to share both the successes and challenges. By the end of 2012, these combined groups attested 22 physicians for a bonus payment of $396,000.
The MU program is set up as a three-stage multi-year endeavor, with Stage 1 focusing on implementing CEHRT and data collection. Subsequent stages build on this, and make more meaningful use of the information being collected and exchanged.
To understand the data that must be collected and reported on, radiology practices need to look at the MU details — the specific criteria, or “measures,” that outline MU requirements. There are multiple measures: a set of mandatory, or “core,” measures; and a set of “menu” measures where providers pick from a menu selection of those criteria that make sense for their practice. One important point for radiology practices and imaging centers to note is that even if a measure is “core,” there may still be a reason to exempt from that measure. For example, there is an e-prescribing measure that states that more than 40 percent of prescriptions must be transmitted electronically, but eligible providers can exclude themselves if they write fewer than 100 prescriptions. Exempting from a measure will not affect the amount of their incentive payment.
As noted earlier, from Stage 1 to Stage 2, the measures go from fairly basic data collection to making more meaningful use of the data collected. One example is providing an electronic copy of the health information record. The Stage 1 measure states that more than 50 percent of requesting patients need to receive an electronic copy of their health information within a certain time frame. The measure in Stage 2 goes deeper, where 50 percent of patients actually receive the electronic copy of health information and 5 percent must actually view, download and/or transmit it to a third party. Obtaining this level of data will involve connections between the radiology practice, the patient and potentially the referring physician. So not only will practices need to be very comfortable with their CEHRT, they will need to have clear connections with their provider community.
The measure that truly brings radiology into the MU discussion is the mandate that more than 10 percent of images and associated reports will need to be accessible through CEHRT. This is going to have a big impact on radiology practices and imaging centers. In order to electronically share images with referring physicians, hospitals will need to image-enable their EHR for access to images and associated reports. Also, it will be mandatory for radiologists to be able to send either the image data or links to image data. As practices look to meeting Stage 1 MU this year, working with a vendor that has a comprehensive plan for image enabling the EHR should be a very important consideration.
One final point to discuss is the hardship exemption. In the past, confusion has reigned over whether MU applied to radiology at all. We believe that MU definitely does apply. However, there are categories through which EPs can apply for a hardship exemption: Lack of infrastructure, EPs facing unforeseeable barriers such as a recent natural disaster, new EPs who have not had time to become meaningful users, EPs that lack face-to-face interaction with patients or lack follow-up, and EPs who practice at multiple locations and lack control over CEHRT availability. Hospital-based radiologists are exceptionally challenged in this regard. While it may be tempting to apply for an exemption and defer MU, recognize that your referring community may not be deferring. For example, if your imaging center works with referring physicians who start MU in 2012, these referring physicians will be planning to move to Stage 2 in 2014. Their expectation in Stage 2 is that they’ll be able to order imaging tests and receive results online. If you’re not able to respond in this way, your referral base may be challenged to continue to send patients to your facilities.
Radiology is now and will continue to be an important part of the meaningful use program. Today, the program offers excellent incentives to use CEHRT and, with reimbursements for imaging declining every year, provide a great way to recover some revenue. Going forward, organizations that have attested will avoid penalties, but more importantly will be better and more tightly connected with their referring communities, including physicians and hospitals. This allows providers to receive the information they need about their patients when they need it, which in the long run will enable better and more efficient patient care. itn
Alicia Vasquez is president of California Medical Business Services, a management services organization serving several clients and two radiology groups, Arcadia Radiology Medical Group (ARMG) and The Hill Medical Corp. She is also past president of Radiology Business Management Association (RBMA) and current president of the Merge Users Group.
Stephanie Hatton is the compliance manager at California Medical Business Services based in Arcadia, Calif.
www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Do.... Accessed May 13, 2013.