On January 29, 2014, Michael Peters, senior director of legislative and regulatory affairs, for the ACR ®, presented a webinar—Navigating the MU Pathway: Stages 1 and 2—sponsored by FUJIFILM Medical Systems. The 30-minute question period following the presentation proved too short to answer all of the questions, so Peters generously prepared answers to the questions that follow.
Radinformatics: Radiology practices have the option of including all patients, or just those with direct radiologist contact, in the so-called denominator. Can you talk about the pros and cons of each option?
Peters: For any meaningful-use objectives with measures that use a denominator of unique patients seen by the eligible professional, the physician is able to define what it means to see patients, as long as all physical encounters and telemedicine encounters with patients are included; the definition is consistent for all such measures, and throughout the reporting period; and the definition does not result in a zero denominator. This is optional, so whether or not a participant uses this flexibility is entirely up to that individual.
On the positive side, this flexibility allows radiologists to have a degree of control over their denominators for those particular measures, and I know of certified products that are specifically designed to codify and leverage this flexibility. Some radiologists, however, might decide not to use this optional flexibility because it could conceivably be more complicated to implement, in an automated fashion, if they are not using products that can easily take advantage of it.
Radinformatics: Stage 2 of meaningful use requires new functionality from an electronic health record (EHR), and vendors are required to be recertified. Is a patient portal one of those requirements, and if so, what functionality must it have?
Peters: First, note that the editions of certification criteria for health IT products used by participants are independent from the stages of meaningful use. In other words, everyone participating in stage 1 and stage 2 of meaningful use this year must use 2014 edition certified products.
Regarding the patient-portal issue in particular, beginning this year, there is a stage 1 and stage 2 meaningful-use objective related to providing patients with the ability to view, download, and transmit certain health information within four business days of the information being available to the physician.
The health information required by CMS for the view/download/transmit objective consists of patient name, provider’s name and contact information, current and past problem list, procedures, laboratory-test results, current medications and medication history, current medication allergies and medication-allergy history, vital signs, smoking status, demographics, care-plan fields, and any known care-team members. You will notice that radiology reports and images are not on that list, but nothing in meaningful use prevents participants from making additional data available to patients through the portal.
Most of these data elements are captured, along the way, for other meaningful-use objectives. When data are not available—because there is no information to record or because the radiologist is excluded from it by another meaningful-use objective (for example, the participant has invoked the exclusion for the vital-signs objective)—the participant is allowed to indicate, in the portal, that the information is not available.
The measure for stage 1 and stage 2 is that more than 50% of unique patients seen by the eligible professional are given this online access to the health information in question within four business days. There is a second measure, for stage 2 participants only, that requires that more than 5% of unique patients seen by the eligible professional (or authorized representatives) either viewed this health information, downloaded it, or transmitted it to a third party.
There is an important exclusion from both measures of this objective if the radiologist neither orders nor creates any of the specific health information that must be available to view/download/transmit (except for patient name and provider’s name), so certain radiologists might conceivably be able to meet that exclusion. If (and only if) they meet that exclusion, they would not need to implement technology certified for the corresponding view/download/transmit certification criterion because view/download/transmit is not in