By focusing on the effective use of electronic health records (EHRs) with certain capabilities, the legislation regarding meaningful use (MU) makes it clear that the adoption of EHRs is not a goal in itself: It is the use of this technology to achieve health and efficiency goals that matters most. While many radiologists have opposed the one-size-fits-all approach to this incentive program, MU clearly impacts the radiology community and is here to stay.
Meaningful use is inevitable, and radiologists who have not started planning an MU strategy shouldn’t wait any longer. According to Data.gov, nearly 600 radiology eligible professionals (EPs) successfully attested to Stage 1 MU as of June 2012. Many took advantage of program exclusions to achieve MU. This article examines the structure of the Centers for Medicare & Medicaid Services (CMS) EHR Incentive Program for Medicare EPs to identify exclusion opportunities and policy guidance that have the potential to alleviate the perceived burdens imposed on medical specialists by this government program.
Take Advantage of Exclusions
In a February 2012 interview, Farzad Mostashari, M.D., national coordinator for health information technology at the Office of the National Coordinator, acknowledged that having a “common platform and common set of measures that all specialties are going to feel are equally relevant to them is a real challenge.” This especially holds true for radiologists who do not typically have direct patient contact.
The meaningful use program was designed to accommodate the variability in physician populations. But due to its one-size-fits-all nature, radiology practices need to adapt some of the core program requirements and acquire new data points to satisfy Stage 1 objectives.
Despite key program objectives and measures that do not perfectly align with typical radiology activities, exclusion opportunities exist. For instance, of the 25 Stage 1 objectives and measures, up to 14 are eligible for exclusion (six “core set” and eight “menu set”), thus having the potential to significantly reduce a radiology professional’s data capture and reporting requirements. As you analyze the full set of core and menu measures and identify potential exclusion opportunities, be sure to create comprehensive documentation to support your decisions.
Developing and implementing a set of well-defined group policies provide a solid foundation when it comes to addressing exclusion opportunities as part of your MU strategy. Moreover, creating standard policies for various activities yields a set of documented interpretations of the regulations as you see fit for your radiology practice.
One example includes establishing a group policy for “seen by the EP” measures. The verbiage “seen by the EP” originally implied that any service rendered by the EP (in this case, the radiologist) should be included in final MU measure calculations. However, guidance released by CMS in June 2011 indicates that a diagnostic radiologist could conceivably choose to limit his or her “seen” patients to physical visits, omitting teleradiology and similar services, for meaningful use measures that include “seen by the EP” verbiage.
While there is flexibility in this language, CMS does require that the EP have a consistent policy regarding when to include or omit these patients from their calculations. In addition, a secondary FAQ was published the same month indicating that when a patient is seen by the EP’s clinical staff and not the EP himself, the EP can elect to include or not include those patients in MU calculations, as long as the decision applies universally to all patients across the required measures.
Now, let’s take a look at the core and menu set objectives that contain “seen by the EP” terminology in their corresponding measures. Based on the guidance discussed above, the following objectives have corresponding measures that may allow EPs to limit their “seen” patients to physical visits only (based on the group policy your organization adopts).
Core Set Objectives With ‘Seen by the EP’ Measures
• 42 CFR §495.6(d)(1): Use computerized provider order entry (CPOE) for medication orders directly entered by any licensed healthcare professional who can enter orders into the medical record per state, local and professional guidelines
• 42 CFR §495.6(d)(3): Maintain an up-to-date problem list of current and active diagnoses
• 42 CFR §495.6(d)(6): Maintain active medication allergy list
• 42 CFR §495.6(d)(5): Maintain active medication list
• 42 CFR §495.6(d)(7): Record demographics: Preferred language, gender, race, ethnicity, date of birth
• 42 CFR §495.6(d)(8): Record and chart changes in vital signs: Height, weight, blood pressure. Calculate and display BMI, plot and display growth charts for children 2 to 20 years (including BMI)
• 42 CFR §495.6(d)(9): Record smoking status for patients 13 years old or older
Menu Set Objectives With ‘Seen By the EP’ Measures
• 42 CFR §495.6(e)(5): Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, medication allergies) within four business days of the information being available to the EP
• 42 CFR §495.6(e)(6): Use certified EHR technology to identify patient-specific education resources and provide those resources to the patient, if appropriate
Consistency is the key here. Once you have defined your group policies, you should create a comprehensive set of compliance records that document your organization’s specific MU policies, measures and exclusions, participants and workflow strategy. Upon completion, you should review these documents with your institutional stakeholders including, but not limited to, your CMO, CIO, MU implementation teams and general counsel. You also should review these documents with departmental stakeholders before implementing your strategy.
Reaping the Benefits of Meaningful Use
Meaningful use has had, and will continue to have, an impact on the radiology community. While exclusion opportunities exist and regulatory clarification offers some guidance for those seeking meaningful use, this government program still introduces a number of challenges for medical specialists.
Even though the regulations are not geared toward radiologists, imaging practices should look at the positive side. In addition to the potential incentive payments (up to $44,000 per eligible professional over the program’s prescribed timeframe), other benefits exist: better data structure, better practice management capabilities and better information that can be preserved in IT systems, just to name a few.
Furthermore, patients will eventually become interested in knowing whether individual providers and hospitals have qualified for meaningful use. Those achieving MU will likely be regarded as offering higher quality care and value than those that fail to qualify. Therefore, it is in the interest of radiologists both financially (incentive opportunity and penalty avoidance) and from the standpoint of practice development to understand meaningful use and take appropriate steps to achieve success with the program. These benefits, coupled with the fundamental shift and widespread acknowledgment of MU’s impact on the radiology community, will lead to a more collaborative advance toward success.
Lastly, advocacy efforts by medical imaging societies and support from the entire imaging community not only have the potential to positively influence future stages of this program, but also the relevance it provides to imaging professionals and positive impact rendered on patient care.
Note: Parts of this article were adapted from The Radiologist’s Guide to Meaningful Use: A Step-by-Step Approach to the Stage 1 CMS EHR Incentive Programs, theMUguide.com.
Jonathon Dreyer is a senior healthcare marketing professional in Boston, Mass.