To hear four radiologists who have immersed themselves in the minutiae of the Health Information Technology for Economic and Clinical Health (HITECH) Act describe it, meaningful use—as it relates to radiologists—is an opportunity, a minefield, and a responsibility that could cost more than the $44,000 per radiologist that can be gained by demonstrating meaningful use of certified electronic health record (EHR) technology.
Nonetheless, Ramin Khorasani, MD; David Avrin, MD, PhD; Keith Dreyer, DO, PhD; and David Mendelson, MD, attempted to cover the meaningful-use waterfront, as it relates to radiology, with a program description, clarifications, caveats, and tips in a session titled “Healthcare Reform Through Meaningful Use of Healthcare IT: Implications for Radiologists,” on November 29, 2010, at the annual RSNA meeting in Chicago, Illinois.
A common thread that ran throughout the presentations was this: Every practice, in every setting, would be well advised to appoint someone to conduct a careful review of the 100-plus–page overview documents (if not the entire 900-page final bill) describing the program. Unless they are willing to risk penalties that will amount to 5% of Medicare payments by 2019, an estimated 90% of radiologists must demonstrate meaningful use of certified EHR technology by 2015.
Khorasani, director, information management systems, Brigham & Women’s Hospital, kicked things off with an overview of the HITECH Act (approved by Congress in February 2009 as part of the broader stimulus act). The initial budget of more than $19 billion was bumped up to about $30 billion in July 2010, with the goal of reforming health care through the adoption of interoperable health records.
“The HITECH law created a mechanism to use stimulus funds to enable a nationwide health-information infrastructure that promotes the electronic use and exchange of information, and it establishes incentive payments for eligible providers and hospitals participating in Medicare and Medicaid programs that meaningfully use certified EHR technology,” he explains. Khorasani emphasizes that it can’t be one without the other: meaningful use and certified EHR technology are both required.
Eligible Providers and Qualified EHRs
To qualify to participate in the program, radiologists must be enrolled with CMS and must qualify for reimbursement under Medicare or Medicaid. The ACR® has estimated that 85% of radiologists qualify to participate under Medicare. Medicaid incentives have a slightly higher dollar amount associated with them, but 30% or more of each individual radiologist’s transactions must be billed under Medicaid—a hurdle that the average practice cannot meet.
All presenters focused on eligible providers, as opposed to eligible hospitals. Khorasani emphasizes that an eligible provider is the individual radiologist, not the practice: The individual radiologist is the eligible provider who has to attest that he or she is a meaningful user of certified technology by applying to CMS. The number of individual radiologists who apply will determine how many dollars flow back to the practice.
For radiologists to participate, more than 10% of their patient encounters (but not the dollars connected to them) must be outside inpatient or emergency-department sites. Radiologists who provide more than 90% of their patient encounters in emergency and inpatient settings are excluded from the program. For eligible providers working in multiple practices, 50% of all patient encounters must be in a practice that meaningfully uses certified EHR technology.
Meaningful use will be implemented in a staged approach. Stage 1, beginning January 1, 2011, focuses on data capture and sharing; stage 2, which will be introduced in 2013, moves on to enable users to perform advanced clinical processes (such as disease management, medication management, decision support, and clinical decision making) through IT; and stage 3 will be rolled out at some future date, with a focus on improving outcomes. At present, the only requirements that have been published are for stage 1 meaningful use.
Eligible providers must use certified EHR technology, either as complete solutions or as modules that enable an eligible provider to qualify for a component of meaningful use. Certifications will be announced by CMS and the Office of the National Coordinator for Health Information Technology (ONCHIT) and posted on their website. The intention