MU Stage 2: Initial Take-homes for Radiology
On August 23, CMS released the final rule for stage 2 meaningful use of health IT. Unlike the stage 1 rule, the stage 2 rule contains myriad radiology-specific portions that might have radiologists in a state of confusion, but things could be simpler than they seem. RadInformatics.com recently conferred with Alberto Goldszal, PhD, MBA, CIO of University Radiology (New Brunswick, New Jersey)—which has already attested to stage 1 meaningful use—and Michael Peters, senior director of legislative and regulatory relations for the ACR®, for clarification of some of the pertinent issues. RADINFORMATICS: What are your initial thoughts on meaningful use—and stage 2, in particular? GOLDSZAL: There is entirely too much focus on stage 2, at this point. Attestation rates for stage 1 have been abysmal. Energy must be focused on change management and on starting to collect the necessary data to move into stage 1, not on what is ahead in stage 2. RADINFORMATICS: What are the implications of stage 2 meaningful use for radiology, and where are the opportunities for radiology to contribute? PETERS: Fundamentally, the new CMS rule is a continuation of stage 1; there have not been many significant changes to the overall framework. We believe the ONC’s final rule will facilitate meaningful-use compliance for practicing radiologists by combining certification criteria for eligible hospitals and eligible providers and increasing flexibility in the definition of certified electronic health record (EHR) technology. The clinical quality-measures (CQM) reporting options contained in CMS’s final rule are better aligned with other quality incentive programs, which should make the CQM reporting process simple for some. Just as important, with the final rule, there are better objective exclusions for radiologists than previously. Also, the issue of the significant-hardship exemption that would allow radiologists and other providers to avoid noncompliance penalties, at least until 2015, is much clearer now. Some may be able to avoid the penalties through 2019, depending upon the specialty codes used in the Provider Enrollment, Chain, and Ownership System. It is still not certain which providers will have this option (and CMS can review and negate the exemption whenever it wants to), so CMS will have to clarify this in future guidance. From the broader perspective of health-care policy, there are obvious benefits to radiologists’ participation in federal government’s efforts to standardize health IT and promote information exchange. The radiology community has seen, up close, how things such as computerized provider order entry with integrated appropriateness/clinical decision support, imaging data exchange, and the like can enhance decision making, thereby improving patient care and safety while reducing costs. RADINFORMATICS: How will the menu objective for including images in the certified EHR for more than 10% of patients affect radiologists, as eligible providers—and as imaging providers to eligible providers and eligible hospitals? PETERS: Most diagnostic radiologists order fewer than 100 tests and will be excluded from this requirement, which is geared toward ordering physicians. I think, though, that this objective could create market demand for electronic access to images and accompanying interpretations. RADINFORMATICS: How will the core objective that enables patients to have access to their test results within four days affect the reports that radiologists might produce? GOLDSZAL: Will radiologists change the verbiage of their reports? I don’t think so. Patients will adapt just fine in terms of getting the essence of their reports, and if not, they will communicate with their referring physicians about it. At worst, we may need to provide, in stage 2, a translation vehicle for patients to use, be it a service available through a nurse or something else. This would definitely be easier than changing our reports, after years of optimizing the workflow around an existing structure (and considering how long it took to implement standardized reporting with defined sections). There are some management issues to think about here, though. If we offer patients an embedded Web link to their studies, as opposed to some other kind of access—such as through a PACS—we need to ensure that the link yields access only to that patient’s dataset, rather than to other patients’ datasets. The Web method presents fewer technical challenges, yet it has issues that cannot be ignored. RADINFORMATICS: There was a change to the exclusion policy whereby the ability to meet an exclusion does not lower the number of menu-set objectives (five) that radiologists must meet, unless they can be excluded from more than five. PETERS: Yes, that is a key change to understand for radiologists currently participating in the program. It’s important to note, however, that the core-menu structure of stage 2 is similar to that of stage 1. Eligible professionals are required to meet the measure for, or qualify for an exclusion from, 17 core objectives and three of the six menu objectives. The core objective of exchange of key clinical information from stage 1 was eliminated in favor of a more robust core objective of transitions of care in stage 2. It’s equally critical to recognize that some objectives have been eliminated, and others have been added. For example, the objective of providing patients with an electronic copy of their health information is off the list. It was replaced by a core objective of viewing online, downloading, and transmitting information that differs a bit from the one suggested in the stage 2 proposed rule. The proposed core objective was to afford electronic/online access to health information. A new eligible-provider stage 2 core objective calls for using electronic messaging to communicate with patients on relevant health information. RADINFORMATICS: The core objective that enables patients to have access to their test results within four days appears to be pushing radiologists toward reporting directly to patients. Are referrers ready to make such a transition? PETERS: While several items in the CMS final rule focus on patient engagement, the ACR is more concerned about the two objectives that pass or fail physicians based on patient action outside of the clinical setting. Some patients may be ready and willing to take those actions, but many may not be. Take geriatric patients. Is it reasonable to expect them to go home and electronically view, download, or transmit their data to a third party en masse, rendering the physician noncompliant with meaningful use if a sufficient number of them do not? RADINFORMATICS: What best practices should imaging providers execute in attesting to meaningful use? GOLDSZAL: Devise policies and procedures that spell out what needs to be accomplished by each different working group/department, which data points need to be recorded for each and every patient encounter, and which protocols need to be followed to achieve compliance on all meaningful-use measures being tracked. This is especially important because with any government incentive, there is the risk of an audit. Avoid implementing technology in a vacuum; everyone, from office staff and assistants to nurses and physicians, needs to be on board and comfortable with it first. Recognizing the major difference between implementation and the actual strategic adoption of meaningful use—in which full organizational commitment is a must—is essential. Just as important, practitioners who have not yet attested to stage 1 should stop fixating on the ins and outs of stage 2 because they will need to remain on stage 1 for two years anyway; they need to start there. Once they have embarked on the road to stage 1 attestation, they will see how the requirements of stage 2 become a roadmap for moving forward. Julie Ritzer Ross is a contributing writer for Radinformatics.com.