ACR Submits Comments on Meaningful Use Stage 3 Regulations

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While generally supportive of most of the goals of Stage 3 of the national electronic health record (EHR) incentive program and its “meaningful use” criteria, the American College of Radiology’s IT and Informatics Committee (ACR ITIC) also registered some reservations this week about the timeline for Stage 3 rule making and some of the specifics in the rule that will impact radiologists and other specialists.

Responding to the Office of the National Coordinator for HIT (ONC) HIT Policy Committee’s request for comments on Stage 3 of the electronic health record (EHR) incentive program, the chair of the ACR Board of Chancellors, Paul H. Ellenbogen, MD, FACR, and the ACR ITIC chair, Keith J. Dreyer, DO, PhD, FACR, urged the following:

1. Slow down to make the best informed rules. While there will be additional opportunities to make changes to the regulations for Stage 3 of the EHR incentive program, and the ACR understood the pressure the ONC is under to move ahead as quickly as possible, Ellenbogen and Dreyer cautioned that the goal of finalizing the policy recommendations around May would not allow time to get input from all stakeholders or from the experience of Stage 2 participants.

They were not alone in this. The American Medical Association, the American Hospital Association and the College of Healthcare Information Management Executives all expressed concern with the ONC’s proposed timeline for finalizing the rules in their comments about Stage 3 of the EHR incentive program.

2. Create more flexibility for non-primary-care physicians. Radiologists and other specialists have struggled with some of the meaningful use objectives because they are aimed at improving primary care and are either irrelevant or a poor fit with specialist medicine. There is a 5-year exception open to radiologists and other specialists who lack they type of face-to-face patient interaction needed for menu objectives like tracking vital signs and providing a written clinical summary for each office visit, but taking it means that radiologists, while spared penalties, also do not get a shot at the incentive payments they may otherwise be due.

Ellenbogen and Dreyer suggested either implementing optional/substitute meaningful use compliance pathways for certain specialists or following the AMA’s suggestion to make the complete list of meaningful use objectives a menu of options from which eligible participants could comply with a set number of objectives that are relevant to their practice.

3. Mandate that clinical decision support (CDS) is part of electronic physician order entry systems for imaging. In particular, the ACR would like its own appropriateness criteria used as the basis for the radiology order entry systems with CDS because the association has research data showing that it reduces inappropriate utilization and all the problems that come along with it, like needless radiation exposure to patients, waste and greater health care costs.

4. Divide the EHR certification criterion for computerized physician order entry systems by specialty. This would help make technology certification requirements stronger and could let products that specialize exclusively in imaging become certified. At the very least, the ONC could creating separate certification criteria for radiology order entry systems.

5. Go ahead with making the accessibility of imaging results through EHR systems a core objective, if the ONC plans to stick with dividing objectives into core and menu items. The ACR stated that it believes that this is a criteria relevant to all clinicians. Furthermore, given the current flexible exclusion options and the requirement of only 10 percent of studies being accessible through the EHR, there are no major barriers to doing so.

6. Move forward with efforts to give patients the option to have their images and dose information transmitted to other health record systems, like personal health records. DICOM and other standards-based transmission protocols already make it possible to view, download and transmit images and dose data, the ACR noted in its comments. The later is particularly important for both patients and physicians to track as it influences the risk versus benefit of future radiology procedures.

7. Don’t mandate a core set of clinical quality measures. The ACR wrote that it supports recommending clinical quality measures, but making certain ones mandatory is a problem for specialists like radiologists