CMS Issues Stage 2 Meaningful Use Final Rule
The Final Rule for Stage 2 Meaningful Use requirements was released Thursday afternoon and it includes many radiology-specific portions. What may prove significant for radiology is the Stage 2 goal of greater use for computerized physician order entry (CPOE). To qualify for Meaningful Use incentive payments, eligible professionals must order more than 30 percent of radiology procedures using a CPOE during the electronic health record (EHR) reporting period. This percentage is a lower threshold than the Centers for Medicare and Medicaid Services (CMS) originally proposed. It had been 60 percent or more of radiology orders. Eligible professionals who write fewer than 100 radiology procedure orders during an EHR reporting period are also exempt from this requirement, the final rule noted. CMS declined to expand its definition of a CPOE to require that it also include computerized decision support (CDS), although it said in the final rule that it agreed with commentators that this was one of the key benefits of CPOEs. Radiology groups such as the ACR have advocated for greater use of CDS to curb inappropriate use of imaging -- as well as tame some of the problems inherent in the review of orders after they are made by third-party radiology benefit managers. Significantly for the outpatient setting, CMS is not requiring that 30 percent of radiology orders be sent electronically to imaging centers as many providers are not ready to receive electronic orders from all varieties of electronic health record (EHR) systems in use by ordering physicians. To qualify, the order just has to be entered electronically. Once in the EHR, it can then be sent to the imaging provider using more traditional means. A second objective of the Meaningful Use Stage 2 regulations is to make Imaging results and information accessible through certified EHR technology (CEHRT). In the Final Rule, CMS clarified that this did not mean that images and their accompanying information be stored in the CEHRT. It simply meant that the CEHRT include a link to where the image and the information can be accessed. CMS also backed off the requirement that 40 percent of images and their results be accessible through the CEHRT and instead set a lower threshold of 10 percent or more with exclusions for providers who order less than 100 scans in an EHR reporting period and for providers who have zero access to electronic images and accompanying data. Acknowledging the difficulty of this requirement for some, CMS made this requirement a “menu item,” meaning that if the infrastructure did not yet exists for a particular eligible professional to get access to electronic versions of more than 10 percent of radiology images ordered, he or she could skip this requirement for now and instead attest for a different “menu item.” CMS also held off on implementing its objective to encourage the exchange of imaging and results between providers because there currently is a lack of information exchange infrastructure to make this easy to accomplish. Finally, for radiologists sweating meeting Meaningful Use requirements that rely on face-to-face/telemedicine interactions and the need for follow up care, CMS created a blanket exception for physicians whose primary specialty is radiology -- as well as anesthesiology and pathology. Radiologists simply have to request an exception from CMS through an application submitted by July 1 of the year before the applicable payment adjustment year to avoid penalties. Click here to access a PDF of the Medicare and Medicaid Programs; Electronic Health Record Incentive Program—Stage 2 Final Rule.