Jonathon Dreyer
Meaningful Use Impact: Diagnostic imaging's billion dollar question
February 08, 2011
This report originally appeared in the February 2011 issue of DOTmed Business News
By Jonathon Dreyer
Although nearly everyone in the medical profession has heard of meaningful use, ambiguity about its impact remains amongst physicians and practice groups. Those with the most unanswered questions include professionals in medical specialties such as diagnostic imaging.
Impact on radiology
While the Centers for Medicare and Medicaid Services and electronic health records incentive programs are clearly geared towards the primary care environment, diagnostic imaging, and many other medical specialties are eligible to participate under the program’s final rule. With more than 30,000 practicing radiologists in the United States, the total incentive opportunity for the diagnostic imaging community is well over $1 billion and penalties for non-compliance could cost the industry hundreds of millions of dollars over the next decade.
At its core, the program consists of three stages, each with a specific set of objectives and measures to be reported on over a prescribed timeframe. With each stage comes the requirement that providers must possess and “meaningfully use” a complete or combination of “certified” EHR technologies. While achieving widespread adoption of certified technology may be more challenging for specialists than general practitioners, there is an increasing number of resources available from specialty societies, industry publishers and online educational centers. In addition, software providers are beginning to offer certified solutions.
While the requirements may appear complex at first, physicians are only called to demonstrate meaningful use for 90 consecutive days in their first year of participation and provide attestation to CMS to receive payment – making deadlines more attainable. Once a health care provider has proven to be a “meaningful user,” and continues to report data after their first year, they will receive annual incentive payments until the program concludes in 2015.
Determining your eligibility and financial impact
The first step in approaching meaningful use is to determine your group’s eligibility and better understand the financial impact of the incentive programs on your individual practice. If you have several physicians with similar practice scenarios, you can aggregate your information and calculate the collective impact.
Let’s begin with eligibility. In order to determine your group’s eligibility you will need to understand what constitutes an eligible professional (EP). As defined by this program, if less than 90 percent of your services are performed in a hospital inpatient (CMS POS21) or emergency room (CMS POS23) care setting you are not considered hospital-based, and therefore, you are eligible to participate in the Medicare EHR Incentive Program as an EP. Based on the definition, approximately 90 percent of practicing radiologists will qualify for the Medicare program.
Determining the financial impact of this program on your imaging practice requires some additional information. To start, you will need to take into account the number of radiologists in your group, your projected enrollment date and whether or not you practice in a Health Professional Shortage Area (HPSA).
Enrollment begins as early as October 2011. The later your practice enrolls and demonstrates meaningful use, the less the incentive payment. Maximum incentives top out at $44,000 per EP; assuming your group enrolls, and successfully demonstrates meaningful use of certified EHR technology by 2012 and meets the minimum annual Medicare revenue of $24,000 per EP. After 2015, those monetary enticements turn into penalties that have the potential to increase annually until meaningful use is achieved.
As for HPSA, if you practice medicine in one of over 6,000 federally identified shortage areas you are eligible to receive an additional 10 percent in incentive payments.
Taking advantage of exclusions
Satisfying the requirements of the Medicare EHR Incentive Program is determined by compliance with stage one meaningful use objectives. All EPs are required to measure and report on 15 “Core Set” and 10 “Menu Set” objectives except when exclusion criteria are met. While variability exists based on practice scenario and patient mix, most radiologists will be excluded from measuring the following core objectives:
- CPOE for medication orders directly entered by any licensed healthcare. professional who can enter orders into the medical record per state, local and professional guideline.
- Record and chart changes in vital signs including: height, weight and blood pressure, calculate and display BM, plot and display growth charts for children 2-20 years, including BMI.
-Generate and transmit permissible prescriptions electronically (eRx).
Most radiologists will also be excluded from measuring the following menu objectives:
-The EP who receives a patient from another setting of care or provider of care or believes an encounter is relevant should perform medication reconciliation.
-Capability to submit electronic data to immunization registries or information systems and actual submission in accordance with applicable law and practice.
-The EP who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care should provide a summary of care record for each transition of care or referral.
For those objectives that you cannot exclude yourself from, you will need to identify the technology that exists in your practice today, discuss certification plans with your IT solution providers and ascertain which certified technology you will need to acquire or create in order to achieve meaningful use compliance.
When performing your analysis, be aware that despite the exclusion opportunities referenced above, your practice must possess certified technology that is capable of measuring all 25 objectives even though you may be able to exclude your practice from reporting their measures.
Developing your meaningful use strategy
At this point it should be clear how important it is for your group to examine your imaging practice, the financial implications, exclusion opportunities and the overall impact of CMS EHR incentive programs. Developing an organized approach coupled with thorough planning will ensure your practice’s success. Strategies will vary based on your specific practice scenarios, but below are five useful tips to help you in the planning process.
Register for the CMS EHR incentive programs now: It is important to register for the appropriate incentive program prior to enrolling and reporting data. Registration began earlier this year and can be completed on the CMS EHR website (https://www.cms.gov/EHRIncentivePrograms/).
Establish deadlines: The earlier your group registers for, and achieves, meaningful use, the larger the incentive payment opportunity. Incentive payments are reduced each year until 2015, when they convert into incremental penalties for every year meaningful use is not achieved. Plan ahead with deadlines in mind.
Analyze your existing IT environment early: In order to receive payments, your organization will need to use certified technology. As part of your strategy you will need to analyze your existing systems, discuss upgrade roadmaps with your vendors (including RIS, PACS, speech recognition, critical communication, decision support and image sharing providers) and conduct a GAP analysis to ensure you have the necessary certified technology in place to achieve meaningful use. Of those measures that you can not achieve with your existing technology, your group will need to (a) acquire certified technology from your existing providers, (b) acquire certified technology from new providers, or (c) create technology in-house that addresses your needs and apply for certification of the technology with an ONC Authorized Testing and Certification Body (ONC-ATCB). Despite technology certification by your vendor, you need to be aware that ONC certification is version dependent and you may be required to upgrade your existing solutions in order to comply with program requirements.
Plan your IT implementations and upgrades of certified technology early: Make sure to plan early and account for any outside projects that play into the timelines you have established – including new technology implementations and critical system upgrades.
Plan beyond Stage One MU: The CMS EHR Incentive Programs take a three-phase approach over the next four years. The more prepared your group is for Stage one, the better suited you will be to successfully meet stage two and three requirements which build upon the foundation established during the first round of objectives and measures.
Future impact
Understanding the impact that meaningful use will have on you and your practice is important. If the medical imaging community fails to comply with meaningful use criteria, hundreds of millions of dollars may be at risk every year, and that number could easily reach the billions if private payers begin to adopt guidelines that mirror federal policy. Staying informed and planning ahead will be the key to your success.
Jonathon Dreyer is the marketing manager for Diagnostic Imaging Solutions at Nuance Healthcare. Dreyer manages a Radiology Advisory Board in addition to working with customers to enhance the company’s solutions portfolio.
By Jonathon Dreyer
Although nearly everyone in the medical profession has heard of meaningful use, ambiguity about its impact remains amongst physicians and practice groups. Those with the most unanswered questions include professionals in medical specialties such as diagnostic imaging.
Impact on radiology
While the Centers for Medicare and Medicaid Services and electronic health records incentive programs are clearly geared towards the primary care environment, diagnostic imaging, and many other medical specialties are eligible to participate under the program’s final rule. With more than 30,000 practicing radiologists in the United States, the total incentive opportunity for the diagnostic imaging community is well over $1 billion and penalties for non-compliance could cost the industry hundreds of millions of dollars over the next decade.
At its core, the program consists of three stages, each with a specific set of objectives and measures to be reported on over a prescribed timeframe. With each stage comes the requirement that providers must possess and “meaningfully use” a complete or combination of “certified” EHR technologies. While achieving widespread adoption of certified technology may be more challenging for specialists than general practitioners, there is an increasing number of resources available from specialty societies, industry publishers and online educational centers. In addition, software providers are beginning to offer certified solutions.
While the requirements may appear complex at first, physicians are only called to demonstrate meaningful use for 90 consecutive days in their first year of participation and provide attestation to CMS to receive payment – making deadlines more attainable. Once a health care provider has proven to be a “meaningful user,” and continues to report data after their first year, they will receive annual incentive payments until the program concludes in 2015.
Determining your eligibility and financial impact
The first step in approaching meaningful use is to determine your group’s eligibility and better understand the financial impact of the incentive programs on your individual practice. If you have several physicians with similar practice scenarios, you can aggregate your information and calculate the collective impact.
Let’s begin with eligibility. In order to determine your group’s eligibility you will need to understand what constitutes an eligible professional (EP). As defined by this program, if less than 90 percent of your services are performed in a hospital inpatient (CMS POS21) or emergency room (CMS POS23) care setting you are not considered hospital-based, and therefore, you are eligible to participate in the Medicare EHR Incentive Program as an EP. Based on the definition, approximately 90 percent of practicing radiologists will qualify for the Medicare program.
Determining the financial impact of this program on your imaging practice requires some additional information. To start, you will need to take into account the number of radiologists in your group, your projected enrollment date and whether or not you practice in a Health Professional Shortage Area (HPSA).
Enrollment begins as early as October 2011. The later your practice enrolls and demonstrates meaningful use, the less the incentive payment. Maximum incentives top out at $44,000 per EP; assuming your group enrolls, and successfully demonstrates meaningful use of certified EHR technology by 2012 and meets the minimum annual Medicare revenue of $24,000 per EP. After 2015, those monetary enticements turn into penalties that have the potential to increase annually until meaningful use is achieved.
As for HPSA, if you practice medicine in one of over 6,000 federally identified shortage areas you are eligible to receive an additional 10 percent in incentive payments.
Taking advantage of exclusions
Satisfying the requirements of the Medicare EHR Incentive Program is determined by compliance with stage one meaningful use objectives. All EPs are required to measure and report on 15 “Core Set” and 10 “Menu Set” objectives except when exclusion criteria are met. While variability exists based on practice scenario and patient mix, most radiologists will be excluded from measuring the following core objectives:
- CPOE for medication orders directly entered by any licensed healthcare. professional who can enter orders into the medical record per state, local and professional guideline.
- Record and chart changes in vital signs including: height, weight and blood pressure, calculate and display BM, plot and display growth charts for children 2-20 years, including BMI.
-Generate and transmit permissible prescriptions electronically (eRx).
Most radiologists will also be excluded from measuring the following menu objectives:
-The EP who receives a patient from another setting of care or provider of care or believes an encounter is relevant should perform medication reconciliation.
-Capability to submit electronic data to immunization registries or information systems and actual submission in accordance with applicable law and practice.
-The EP who transitions their patient to another setting of care or provider of care or refers their patient to another provider of care should provide a summary of care record for each transition of care or referral.
For those objectives that you cannot exclude yourself from, you will need to identify the technology that exists in your practice today, discuss certification plans with your IT solution providers and ascertain which certified technology you will need to acquire or create in order to achieve meaningful use compliance.
When performing your analysis, be aware that despite the exclusion opportunities referenced above, your practice must possess certified technology that is capable of measuring all 25 objectives even though you may be able to exclude your practice from reporting their measures.
Developing your meaningful use strategy
At this point it should be clear how important it is for your group to examine your imaging practice, the financial implications, exclusion opportunities and the overall impact of CMS EHR incentive programs. Developing an organized approach coupled with thorough planning will ensure your practice’s success. Strategies will vary based on your specific practice scenarios, but below are five useful tips to help you in the planning process.
Register for the CMS EHR incentive programs now: It is important to register for the appropriate incentive program prior to enrolling and reporting data. Registration began earlier this year and can be completed on the CMS EHR website (https://www.cms.gov/EHRIncentivePrograms/).
Establish deadlines: The earlier your group registers for, and achieves, meaningful use, the larger the incentive payment opportunity. Incentive payments are reduced each year until 2015, when they convert into incremental penalties for every year meaningful use is not achieved. Plan ahead with deadlines in mind.
Analyze your existing IT environment early: In order to receive payments, your organization will need to use certified technology. As part of your strategy you will need to analyze your existing systems, discuss upgrade roadmaps with your vendors (including RIS, PACS, speech recognition, critical communication, decision support and image sharing providers) and conduct a GAP analysis to ensure you have the necessary certified technology in place to achieve meaningful use. Of those measures that you can not achieve with your existing technology, your group will need to (a) acquire certified technology from your existing providers, (b) acquire certified technology from new providers, or (c) create technology in-house that addresses your needs and apply for certification of the technology with an ONC Authorized Testing and Certification Body (ONC-ATCB). Despite technology certification by your vendor, you need to be aware that ONC certification is version dependent and you may be required to upgrade your existing solutions in order to comply with program requirements.
Plan your IT implementations and upgrades of certified technology early: Make sure to plan early and account for any outside projects that play into the timelines you have established – including new technology implementations and critical system upgrades.
Plan beyond Stage One MU: The CMS EHR Incentive Programs take a three-phase approach over the next four years. The more prepared your group is for Stage one, the better suited you will be to successfully meet stage two and three requirements which build upon the foundation established during the first round of objectives and measures.
Future impact
Understanding the impact that meaningful use will have on you and your practice is important. If the medical imaging community fails to comply with meaningful use criteria, hundreds of millions of dollars may be at risk every year, and that number could easily reach the billions if private payers begin to adopt guidelines that mirror federal policy. Staying informed and planning ahead will be the key to your success.
Jonathon Dreyer is the marketing manager for Diagnostic Imaging Solutions at Nuance Healthcare. Dreyer manages a Radiology Advisory Board in addition to working with customers to enhance the company’s solutions portfolio.