January 4, 2010 - In the Office of the National Coordinator's (ONC) proposed regulations for certification criteria and standards for achieving "meaningful use" for electronic health records, released on December 30, 2009, it specified the use of e-prescribing, electronic exchange of health information, and data on clinical quality measures. These proposed regulations are currently open to discussion during a 30- to 60-day public comment period. The “meaningful use of certified electronic health record (EHR) technology” incentives program, authorized by the American Recovery and Reinvestment Act, will provide billions of dollars in to providers and hospitals for the "Meaningful Use" of certified health IT products. Non-hospital-based eligible professionals can participate in either the Medicare program or the Medicaid program. However, it is unlikely that many non-hospital-based radiologists will meet the threshold for Medicaid incentives. Instead they can qualify for Medicare program for providers, which is restricted to non-hospital-based physicians. ARRA also established a different meaningful use program for hospitals, but not for physicians in hospitals. This “non-hospital-based” distinction exists because hospital-based physicians are expected to use the facilities and equipment (including the EHR technology) provided to them by the hospital. The Medicare incentive payments are for the “meaningful use” of certified EHR technology, and not for the purchase, implementation, or maintenance of EHR products. ARRA indicates that meaningful use must entail: 1) the use of e-prescribing as determined to be appropriate by the Secretary of HHS; 2) connection of the certified EHR technology in a manner that provides for the lawful electronic exchange of health information to improve the quality of health care; and 3) the submission of information, in a form and manner specified by the Secretary of HHS, on clinical quality measures and other measures selected by the Secretary of HHS. For an electronic health record system to qualify as “certified EHR technology” the product must include patient demographic and clinical health information (such as medical history and problem lists) and have the capacity to 1) provide clinical decision support, 2) support physician order entry, 3) capture and query information relevant to health care quality, and 4) exchange electronic health information with, and integrate such information from other sources. Regarding radiology information systems, the American College of Radiology indicates on its Web site the following: “It is unlikely that most existing RIS and/or PACS products would meet the necessary requirements, although the legislative language gives a certain degree of flexibility to regulators as to what constitutes EHR technology. It is important to note that ONC is exploring developing one or more modular/component HHS certification pathways for non-comprehensive EHR technologies. Some type of modular/component certification could prove to be important to a specialty like radiology which may not utilize all the functionalities and options of comprehensive EHR products.” Medicare and Medicaid incentive payments start October 2010 for hospitals and January 2011 for eligible provider categories. For more information: www.acr.org
October 25, 2026 
