Fujifilm Builds a Foundation for Meaningful Use
With the definition of meaningful use coming into greater focus, radiologists have seen their initial disappointment at not being invited to the party evolve into the realization that they must demonstrate meaningful use of health IT or risk penalties in 2015. Radiology practices bear the burden of assessing readiness and preparing a strategy, but imaging IT vendors will also play a critical role in preparing their systems for certification, either as qualified electronic health records (EHRs) or certified EHR modules. At FUJIFILM Medical Systems USA, Inc, Stamford, Connecticut, that effort began with gathering the facts, conducting an internal analysis, and hiring a consulting company to help guide product enhancements that will position the Synapse RIS to be certified as a qualified EHR. “Health-care providers must deliver and demonstrate quality care to their patients, and at the same time, balance the economics and regulatory requirements,” according to Jim Morgan, vice president of medical informatics for Fujifilm. He says, “Our modern RIS architecture and speed of development allow us to adapt quickly to these new guidelines, and we will be in the forefront of the market incorporating these new features. Users of our product will be able to achieve this balance and not sacrifice patient care or be economically challenged.” While the initial proposed definition of meaningful use from CMS and the Office of the National Coordinator for Healthcare IT appeared to bar radiology practices from participating in the Health Information Technology for Economic and Clinical Health (HITECH) program as eligible providers, the final rule (released in July 2010) indicates that approximately 85% of all radiologists are considered to be eligible providers under the rule, according to the ACR®, and are therefore required to participate or risk pay cuts. Just the Facts There are five game-changing ideas for radiology included in the final rule. First, the definition of an eligible provider was amended to include all physicians except those who bill under place-of-service codes 21 (inpatient) and 23 (emergency). The final rule removed outpatient hospital settings (code 22) from the hospital-based designation. Second, instead of having to report all 25 meaningful-use measures, eligible providers need only report on 15 core measures and choose five out of 10 menu measures, introducing a flexibility not included in the preliminary rule. Third, several meaningful-use measures now feature exclusion criteria to account for differing scopes of practice. For example, if an eligible provider writes fewer than 100 prescriptions during the reporting period, he or she would be excluded from the electronic-prescribing measure. Contrast media are considered a supply, not a medication. Fourth, if an eligible provider meets an exclusion criterion for one of the menu-set measures, then the eligible provider would select four (instead of five) of the remaining nine menu-set measures. Fifth, payment penalties will be introduced in 2015 for eligible providers who fail to demonstrate meaningful use. Synapse RIS As a Qualified EHR In its effort to sort the facts from the misinformation in the marketplace, Fujifilm has determined that imaging—and therefore, PACS—is not among stage 1 requirements. Stage 1 requirements call for the electronic capture of data that are typically collected by primary care. Fujifilm also has determined that with EHR-specific product-development modifications, Synapse® RIS has the opportunity to become certified as a qualified EHR, and therefore, could potentially qualify practices for funds under the HITECH Act during the first year of the program. The rule defines a qualified EHR as an electronic record of health-related information on an individual that includes patient demographic and clinical health information, such as medical history and problem lists, and that has the capacity • to provide clinical decision support; • to support provider order entry; • to capture and query information relevant to health-care quality; and • to exchange electronic health information with, and integrate such information from, other sources. An initial product analysis has determined that clients using Synapse RIS meet eight out of the 15 core requirements today and can perform three out of the four needed menu set requirements (radiologists can be excluded from submitting data to an immunization repository, so they are only required to meet four of five menu-set requirements). “We are undergoing a complete analysis of the current offering and determining the exact features/functions that are missing,” Morgan says. “We will be providing these functions as part of a software update to the system in 2011.” $44,000 per Radiologist To qualify for an incentive payment under the Medicare program for a given payment year, an eligible provider must meaningfully use a certified EHR technology for the duration of the EHR reporting period of the relevant payment year. In order to demonstrate meaningful use, eligible providers must report on EHR use in any continuous 90-day period within the first payment year, and during the entire calendar year for all subsequent years. This 90-day/first-year concept means that eligible providers could begin their EHR reporting period late in their first payment year. The sooner physicians position themselves to demonstrate compliance with year-one objectives, the larger the payment: Eligible providers who demonstrate compliance with year-one objectives in 2011 or 2012 can qualify for up to $18,000, with the payments dropping off to $15,000 in 2013 and to $12,000 in 2014. The demonstration of meaningful use through subsequent stages can qualify each eligible provider for additional payments, up to a maximum of $44,000 per radiologist. “Our product-development timetable will allow our clients to qualify for funds in the first year, particularly since the requirements allow for only a 90-day consecutive use of a certified product during the first year only,” Morgan promises. Fujifilm has retained a third-party meaningful-use consulting company to guide it through the certification effort, which will begin with an analysis of the current Synapse RIS product offering, the identification of product gaps, and the development of feature enhancements to ensure that the RIS covers all applicable criteria. When product development has been completed, Fujifilm will present the Synapse RIS product to an authorized body for testing and modular certification. In stages 2 and 3—kicking off in 2013 and 2014—meaningful use expands to include the promotion of quality; structured information exchange; and safety, efficiency, and population-health improvements. Under these requirements, PACS and RIS, if certified as EHR modules, could potentially help eligible providers demonstrate meaningful use of health IT. Cheryl Proval is editorial director of Radinformatics.com and vice president, publishing, imagingBiz, Tustin, California.