AuntMinnie.com is pleased to present the next installment of Leaders in Imaging, a series of interviews with individuals who are shaping the radiology landscape. We spoke with Keith Dreyer, DO, PhD, vice chairman of radiology for informatics at Massachusetts General Hospital in Boston. Dreyer is also an associate professor of radiology at Harvard Medical School in Boston and corporate director of medical imaging for Partners HealthCare.
At the upcoming RSNA meeting in Chicago, Dreyer will participate in several sessions aimed at educating radiology practices and vendors on the meaningful use requirements for U.S. providers to receive healthcare IT stimulus funding. He will also give a presentation on meaningful use at 12:00 p.m. EST on November 17 during PACS in an Age of Change: An AuntMinnie Virtual Conference. For more information and to register for free, click here.
AuntMinnie: There doesn't seem to be a great understanding in the medical imaging community of how the meaningful use requirements to qualify for U.S. healthcare IT stimulus funding relate to radiology. Could you help clear up that picture?
Dreyer: We, at the American College of Radiology, believe that nearly all practicing radiologists are now eligible for the [U.S. Centers for Medicare and Medicaid Services (CMS)] meaningful use [electronic health record (EHR)] incentive program. Keeping in mind that this distinction affords radiologists not only the incentives for participation but also all the penalties for nonparticipation, it's something that cannot be ignored.
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| Keith Dreyer, DO, PhD, vice chairman of radiology for informatics at Massachusetts General Hospital. |
However, the final rule added Place of Service Code 22 (Outpatient) to the definition of an [eligible professional], which includes such activities as outpatient imaging. This change alone has made approximately 90% of practicing radiologists in the country eligible for the meaningful use program. There is a great tool that can help you determine if you are eligible, located at www.radiologyMU.org. It also helps determine the financial impact to your specific group.
What specific radiology informatics technology do you expect will qualify under meaningful use?
So, if you are eligible for meaningful use and you wish to participate in the program, you will need to be using technology that is certified [by one of the testing agencies authorized by the U.S. Office of the National Coordinator for Health Information Technology (ONC)]. Typically, people think of this as EMR [electronic medical record], but it's actually any IT technology can be submitted for certification. If a product does not meet all criteria for certification, it can be submitted for modular certification. This is the pathway that I see most radiology IT products heading toward.
In the radiology domain, there's no question that you will begin to see modular certification of IT products. These will include RIS, PACS, reporting systems, decision-support systems, image sharing systems, patient image portals, business analytics, and data mining, just to name a few.
The challenge for radiologists and group managers will be to determine which products, when integrated, will supply them the functionality and certification criteria they need to qualify their group for meaningful use. Again, there are tools like this one here to help groups with this process.
Can you share some common scenarios for how radiology practices might qualify for meaningful use, and how much funding they would qualify for?
In terms of planning for [meaningful use], I tend to think of practices falling into the following categories: hospital-based, group practice-based, and imaging center-based. Naturally, most practices do not work exclusively in any one of these categories, but these distinctions help to organize an otherwise complex discussion. For those finding themselves in several of these categories, it is best to think in terms of which category most of your CMS work is performed.
If you practice in a hospital setting, you should speak with your chief information officer immediately to understand their institutional plan for [meaningful use], which should include other [eligible professionals] at your facility as well. In this scenario, you may be able to leverage your facility's certified EMR products along with your modular certified RIS, PACS, and other components in order to achieve a fully certified IT environment. If your hospital does not plan to implement a certified EMR, then you will need to acquire more certified technology within your radiology department.
If you're predominantly in a group practice setting, speak with your medical director to determine if the group will be participating. If so, your group will most likely be purchasing a certified EMR. In that case, you can follow the pathway discussed above for hospital settings. If not, you will need to ensure your radiology department has enough modular certified technology to cover all meaningful use measures.
Finally, for imaging centers, there will probably be no certified EMR to leverage, so you will need to ensure that your group has enough modular certified technology to cover all [meaningful use] measures. I suspect most groups in this category will rely on radiology IT vendors to supply these modular certified products, allowing them to qualify.
As for how much funding you qualify for, again, I would recommend using the tools here to calculate your individual financial impact; for larger groups, the number is in the millions of dollars.
Will existing systems also qualify for meaningful use? And if so, how will this work?
Existing systems such as RIS, PACS, reporting, etc., that participate in [meaningful use] will all need to be certified. As I mentioned earlier, most radiology systems will be modular certified, and the exact number of criteria that each product will be certified for -- up to 44 certification criteria are available -- will vary widely from vendor to vendor. All of us need to check with our vendors to understand their strategy for meaningful use and plans for certification of their products.
What are the timeline and key dates that radiology practices should be aware of?
You should definitely begin your planning right away. In order to obtain the maximum incentives allowable, you will need to have all certified technology in place being used "meaningfully" no later than October 1, 2012. And, with the effort it will take to select and implement products, create and implement new workflows, and educate your staff, there is really not a lot of time.
What are some practical tips to help radiology practices make sure they qualify?
You should be reviewing all 25 [meaningful use] measures to determine which, if any, you may be excluded from.
How should radiology practices work with their vendors to ensure meaningful use? How will the certification process work?
Meet with your vendors now to ensure that their products will be certified and will provide all the necessary criteria that you will need to achieve meaningful use.
The vendor certification process can be complex and lengthy. Prior to their submission of products for certification and testing, vendors will need to closely compare their products' functionality against all 44 [National Institute of Standards and Technology (NIST)] criteria. Any gaps in functionality or improper use of standards will need to be rectified prior to the submission process. This may take several iterations of software modifications, so it is best to impress upon your vendors how important it is for them to begin this process immediately.
What can radiology practices expect in the future from the health IT stimulus program?
Clearly, stage 1 of meaningful use approaches eligible professionals as a single type of physician, targeted mainly at primary care physicians. It is this "one size fits all" approach to the [meaningful use] measures that has made radiology participation so complex and somewhat misguided.
We, at the American College of Radiology and RSNA, are working aggressively with the relevant federal agencies in attempts to make stages 2 and 3 of meaningful use more specialty directed. Areas where we hope to direct [meaningful use's] focus as it applies to radiology include image sharing, clinical decision support for radiology ordering, structured outcome reporting, and radiation dose registries.
By Erik L. Ridley
AuntMinnie.com staff writer
November 17, 2010
Related Reading
CCHIT launches EHR certification program, November 11, 2010
Leaders in Imaging: A conversation with William Hendee, PhD, October 13, 2010
ONC clarifies 'meaningful use' certification rules, September 30, 2010
Meaningful use: Comply and get paid ... but how? August 23, 2010
Final meaningful use rules: What radiologists need to know, July 29, 2010
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