Journal of American College of Radiology issued a wake-up call for radiologists in its September issue, reminding them that a collective $1.5 billion in incentives, or $44,000 per individual radiologist, is at stake with meaningful use (MU) reporting.
Tom Gibbings, MBA, of DR Systems in Santa Fe, Calif., and colleagues attempted to dispel lingering MU myths that radiologists have not been left out of MU bonus payments. And while compliance is not technically impractical, as some radiologists have assumed, it will be challenging, the authors said.
Although radiology represents the most computerized physician specialty, MU regulations require physicians to install and use additional technology in specific ways that do not readily integrate into the radiology workflow.
Gibbings and colleagues reviewed the alphabet soup of MU, explaining that the Office of the National Coordinator of Health Information Technology has specified the functional criteria for certified EHRs. Meanwhile the Centers for Medicare & Medicaid Services (CMS) has developed the clinical objectives regarding how the technology must be used to qualify for bonuses.
CMS objectives will be rolled out in three stages. Stage 1 addresses standardized data capture, tracking key clinical conditions, communication, decision support and reporting of quality measures and public health information.
Subsequent stages—2 and 3—slated for 2013 and 2015, respectively, address quality, safety and efficiency.
The authors noted that current RIS and PACS do not meet the technology criteria, which forces radiologists to add technology and modify workflow to meet measures such as vital signs reporting.
“Although it is certainly true that radiologists will need to adapt, there is perhaps a silver lining: the requirements for interoperability of such items as the patient problem list, allergies, medications and immunizations may finally provide radiologists the critical clinical information needed to provide the best possible patient care,” wrote Gibbings et al. In addition, data collection as specified by MU may improve billing and collections, they noted.
Meeting the technological criteria and clinical objectives of MU does represent a bit of a land mine. For example, although radiologists are exempt from some objectives such as e-prescribing because they do meet the baseline requirements of prescriptions, they must still install the technology to meet the requirement. “As illogical as it may seem, it is the law,” wrote Gibbings and colleagues.
Hospital-based radiologists must document the use of complete certified EHRs installed in their organizations, which requires these physicians to collaborate with the hospital to ensure that the technology is presented in the context of radiology workflow.
Radiologists who practice at a hospital and an outpatient office or imaging center must use a complete certified EHR at the organization where they practice at least 50 percent of the time. This may require tracking the point of service of all activities. If the situation applies to a radiology group and only one organization uses a certified EHR, scheduling may become a challenge because each radiologist would need to demonstrate that more than 50 percent of encounters occurred at the site equipped with the certified technology.
Deadlines, details & recommendations
The first registration deadline is Oct. 1, 2012; it is the final day that a physician can begin using technology to qualify for maximum incentives of $44,000. The next key date is Oct. 1, 2015, the last date to begin compliance before incurring penalties.
Gibbings and colleagues recommended that radiologists learn about the required technology and clinical objectives, using the American College of Radiology, CMS and U.S. Department of Health and Human Services as resources. They noted, “Even if meaningful use compliance seems to be too much trouble relative to the bonus payment available in the early stages, assuming the current regulations stay in effect, compliance will be required to avoid subsequent penalties.”
The authors recommended that radiologists become active participants in the hospital planning process to ensure representation. They also suggested that radiologists and administrators continue to survey the marketplace to locate systems designed with radiologists in mind. (Such systems may not yet be commercially available.)
“The bottom line,” the authors concluded, “is