Embarking on the Meaningful-use Path

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Jim MorganReynold YordyHow elusive is the goal of meaningful use among imaging groups? We know of only a handful of US radiology practices that have qualified. Relying on in-house talent is a great way to get it done, but not many practices have the personnel needed to research the complexities involved. Selecting and deploying the correct technology, and then attesting to receive incentive payments, are no small tasks. A meaningful-use consultant can be an excellent idea, and there are regional extension centers throughout the United States designated to help with this, in addition to a list of consultants available at www.radiologymu.org. Even with a consultant’s help, many staff members might look at the new responsibilities and quickly conclude that meaningful use is just one more task that they must do for the benefit of the radiologist’s wallet. To avoid this dissatisfaction, emphasize that the overall CMS plan is to improve the quality of patient care and reduce redundant and unnecessary procedures. In addition, staff members should know that there are potential cuts in reimbursement for noncompliance (a penalty that helps no one).
Meaningful-use FAQMeaningful use is a government initiative, created as part of the American Recovery and Reinvestment Act of 2009, designed to encourage providers to use health-care IT solutions to improve the quality of care while lowering costs. The initiative provides incentive payments to eligible providers using a certified electronic health record in a meaningful way.
Unfortunately, some groups are just focusing on how to avoid penalties and get their electronic health record (EHR) incentive payments—disregarding the overall effect on the practice. Stay away from this line of thinking,and view, instead, the meaningful-use mandate as an excellent time to select the best RIS to run the practice. In your search for a RIS, choose a vendor that has complete EHR certification and a clear roadmap for meaningful-use completion by the end of the year. The functionality of the RIS should be the core focus, with the EHR as just one requirement. Many Radiologists Qualify Resist the temptation to dismiss meaningful use as something that does not apply to your practice. Many more radiologists qualify for the program than analysts originally thought. Because hospitals bill out a great number of imaging exams with an outpatient place of service, even many hospital-based radiologists will qualify.
Who Is Eligible?
  • If 10% or more of your patient encounters are not coded as inpatient or emergency-department encounters when you submit your claims to CMS, then you may qualify for the CMS incentives.
  • To determine which radiologists qualify as eligible professionals, visit this CMS site.
If meaningful use applies to your practice (and it probably does), be aware that you can choose to bypass stage 1 and wait for stage 2. Proposed rules for stage 2 requirements were posted to the Federal Register on February 23, 2012, and will be open for public comment for three months. The proposed rule would require practices that attested to meaningful use in 2011 to spend an extra year in stage 1, and would delay the start of stage 2 attestation until 2014. Practices that choose to wait will sacrifice some incentive money, but they could have fewer headaches. If you decide to wait and begin to attest in 2014, we believe that you can start immediately under stage 2 guidelines. As proposed, it appears that these guidelines will be a bit more relevant to what a radiology practice actually does. Nonetheless, it would be imprudent to make a decision based on a proposed rule.
What Is Required?
  • Register each qualified radiologist as an eligible professional.
  • Purchase and implement a certified complete electronic health record. Synapse RIS(FUJIFILM Medical Systems USA, Inc) is on track for certification in July 2012 to enable providers to qualify for incentive payments in 2012.
  • Begin use of the product for attestation while achieving the minimum thresholds for measures to be reported.
  • Submit attestation data.
An additional stage is anticipated but it has yet to be defined. We know that application vendors will be required to upgrade their software continually to meet the latest criteria, and providers will be required to meet and attest to new requirements and measurements. Therefore, selecting a long-term partner with a proven track record is important. Penalties and Rewards Why did so few practice representatives choose to attest last year? The short answer is that many hoped that meaningful use was going to go away, while others hoped that it would change to represent radiology better. There still are a number of groups hoping that if they close their eyes and jam fingers in their ears, meaningful-use requirements will somehow stop. Another faction sees a bit of money out there, and in reality, it’s about a $5,000 difference between attesting this year ($44,000 per radiologist) and starting attestation next year ($39,000 per radiologist). We are currently working with a number of customers with a variety of mindsets. Some are current customers, and others are actively working toward making a RIS decision—to begin their attestation and start using the technology by the October 3, 2012, deadline.
How Much Are the Incentive Payments?
Year Eligible Professional Qualifies to Receive First Payment
Payment Year 2011 2012 2013 2014 2015
2011 $18,000
2012 $12,000 $18,000
2013 $8,000 $12,000 $15,000
2014 $4,000 $8,000 $12,000 $12,000
2015 $2,000 $4,000 $8,000 $8,000
2016 $2,000 $4,000 $4,000
Total $44,000 $44,000 $39,000 $24,000
At this point, we are encouraging customers to proceed with some urgency, especially if they have not yet bought a RIS. After all, they are going to have to learn a whole new system and figure out how to do things in the context of a particular workflow, and it might be quite different from their previous systems. RIS decisions should be made in the coming weeks for practices to be prepared to attest by October 3. We recommend using the technology for a minimum of 15 to 30 days before starting attestation. The last thing we want is for a practice to begin using the RIS on October 3, spend a month collecting data, and then realize that it was not collecting the necessary data—and thus can’t attest.
2012 Stage 1 Key Dates
  • October 3, 2012: Begin use of certified complete electronic health record for attestation purposes by this date.FUJIFILM Medical Systems USA, Inc, recommends that clients use the system for at least two weeks prior to this date to ensure that all necessary data are being collected prior to the beginning of the attestation period.
  • February 28, 2013: Submit data for attestation to stage 1 meaningful use in 2012 no later than this date.
For those who choose not to comply with meaningful use, there will be a reimbursement penalty, beginning in 2015, applied to both technical and professional fees. It’s not an enormous hit, but penalties of up to 3% can add up to a significant number.
MU Change Management
  • A number of criteria that are required are most likely not to be performed as a routine part of the practice of radiology today. FUJIFILM Medical Systems USA, Inc, has incorporated appropriate pieces into the registration and order entry process in its Synapse RIS to minimize the overall effect on a practice’s workflow.
  • We encourage each practice to assess what methods it will use to gather these additional data, what requirements it can be excluded from, and any costs associated with the modification of workflow.
Whether you choose to start down the meaningful-use path in 2012 or later, begin the journey with the purpose of preparing your practice for the demands that lie ahead. The ability to deliver and demonstrate high-quality care while operating on reduced reimbursement rates can be enhanced through the thoughtful application of health IT. Jim Morgan is vice president of medical informatics for FUJIFILM Medical Systems USA, Inc. Reynold Yordy is director of information-systems marketing for the company.