7 Steps. Federal ambulatory meaningful use (MU) regulations provide potential bonus. for Implementing Meaningful Use

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1 7 Steps for Implementing Meaningful Use What does meaningful use really mean to you and for the future of medical imaging? Murray A. Reicher Cofounder and Chairman of DR Systems Cofounder of Health Companion Federal ambulatory meaningful use (MU) regulations provide potential bonus payments of $1.5 billion to radiologists over the next four years, with looming penalties for those eligible providers who do not comply. Even though hundreds of radiologists have already implemented complete certified ambulatory electronic health records (EHRs) and have received their first $18,000 installment on a SPRING

2 $44,000 expected incentive payment, the vast majority of radiologists still have taken no meaningful action. Most radiologists still seem to believe the program is not for them. Approximately 90% of radiologists are eligible providers as defined by the incentive program with bonus payments of well over $1 billion still available for them. This paradox raises several questions: How Meaningful Use Began MU incentive payments were introduced into federal law as part of the American Recovery and Reinvestment Act of The core idea was to promote the use of standards-based EHRs to achieve several goals: between providers and computer-aided decision support These goals seem noble, especially in view of our nation s high health care expenditures and nonideal outcomes, such as high obesity rates (up to 38% in some states), undiagnosed or undertreated hypertension (in nearly 40 million Americans), high tobacco-related health care costs (as much as $170 billion per year), poor immunization compliance (contributing to 30,000 35,000 influenza-related deaths per year), and poor compliance with well-understood screening measures (e.g., mammography, colonoscopy, and skin cancer screening). We face a health crisis, resulting in a health care financing crisis, which is a chief cause of our federal budget deficit, in turn resulting in a national economic crisis, which ultimately threatens our standard of living and peace of mind. With this understanding, and with acknowledgement of the potential for MU to improve the situation, it seems irresponsible for radiologists to close their eyes to the strategic opportunities now available. Under Stage 1 of the federal law, each provider who receives Medicare payments of a minimum of $24,000 per year is still eligible for up to $39,000 in bonus payments per physician over the next four years, provided that more than 10% of services are performed in the outpatient setting as defined by the following Centers for Medicare and Medicaid Services (CMS) place of service (POS) codes [1]: Because the POS 22 code was not included in the initial proposed ambulatory physician incentive payment criteria, most radiologists staffing hospitals would have been excluded. However, when POS 22 was subsequently included among the outpatient criteria, the vast majority of radiologists became eligible providers. Later, when Stage 2 MU regulations were announced in fall of 2012, the criteria for opting out loosened. As a result, in a two-year span from after the Health Information Technology for Economic and Clinical Health (HITECH) Act (aka Obamacare ), conventional wisdom among radiologists fluctuated from thinking, we re out, to we re in, to we re opting out. This vacillating course is perhaps the chief reason why such a low overall percentage of radiologists have participated to date, unlike most of our clinical colleagues. 6 SPRING

3 Regardless, one thing is certain: the national implementation of certified EHRs has far surpassed the tipping point. The vast majority of hospitals now employ complete certified inpatient EHRs, and more than half of all hospitals and physicians now employ complete certified ambulatory EHRs as well. Furthermore, virtually the entire health information technology industry has embraced the MU standards and certification programs. In fact, the adoption of MU-compliant health information technology most likely represents the fastest life cycle in the history of technology. There is no longer any question whether MU will happen; rather the only remaining question for radiologists is how they will be affected and how the resultant opportunities can be leveraged. 7 Steps for Implementing Meaningful Use To build a logical case for appropriate implementation of MU technologies and workflows, one must first understand a series of seven logical pillars that form the foundation for strategic planning. 1. Understand What Is Really at Stake for EHR Incentive Programs. We live in a world where the vast majority of our hospitals and professional colleagues have technologies that for the first time can actually exchange information based on widely adopted MU standards. They may not all realize they can do it, and they may not be doing it yet, but the fact remains that they have implemented systems that can speak to each other. The U.S. health care Internet has essentially been successfully seeded. In a world where radiologists are already suffering from commoditization, do we seriously think it is a good idea to become electronically isolated from our patients and colleagues? 2. Consider Patient Engagement Carefully. Your strategy for MU must strongly consider the increasing need for patient engagement via personal health records. Whether you attend a health care professional meeting, health information technology meeting, or insurance industry meeting, the buzzwords you hear now are consumer engagement and patient engagement. Why? A constellation of social changes, including the greater transparency of medical records provided by MU, the rise of highdeductible health care plans, the increasing financial rewards that employers can provide employees for preventive behavior under the HITECH Act all add up to a new reality: consumers are increasingly taking responsibility for selecting their providers. Any provider organization that is not consumerfriendly is in trouble today. MU technology provides a standardized way to communicate with patients and referring doctors. How long will it be before your patients ask, How come I can get an electronic copy of my health information from my internist that I can download to my personal health record, but I can t get it from you? Or perhaps they will say, At your competitor s facility, I can preregister and provide all the appointment information There is no longer any question whether MU will happen; rather the only remaining question for radiologists is how they will be affected and how the resultant opportunities can be leveraged. Murray A. Reicher SPRING

4 via the Internet. Why not here? Or, The other guys let me obtain my radiology report and medical images and keep them in my personal health record. Even worse, the patient might say, I have no idea who my radiologist is because I never met him, and I receive no post-visit communication from him, unlike my other doctors. The federal MU program now provides a one-time chance to solve these problems with technology the government is willing to fund. 3. Don t Opt Out of the Program by Claiming Hardship. As already noted, we are now well past the tipping point for MU market penetration. In addition to the opportunities MU provides to increase direct communication with patients, soon you will be receiving requests from referring physicians who expect you to be able to receive a clinical summary from them and electronically deliver a clinical summary (radiology report) back to them. Under Stage 1 of the EHR incentive program, one of the elective ( menu set ) items requires that participants provide clinical summaries whenever there is a transition of care (e.g., after an outpatient visit). Under Stage 2, this becomes a mandatory objective, so your referring doctors who are participating in the EHR incentive program will be demanding electronic information exchange. All radiologists should value this opportunity because one of the chief causes of radiological errors is clinical myopia, that is, a lack of awareness of the patient s entire relevant history. Soon, expect your referring doctors to start asking, Why can I send a clinical summary to my other consultants who are MU participants and not to my radiologists? Furthermore, they may say, I m not sending a patient to a facility that makes me fill out paperwork anymore, and I m not referring to a radiologist consultant who does not have the patient s full history. Those days are over. Radiologists and imaging facilities (including hospitals) that opt out of the EHR incentive program claiming hardship are losing a one-time chance at federal funding for technology that will be a must have in the near future. This means they will be opting out of an incentive payment that is available for a short time only. There is no opting out of the realities that MU is here and that there will be long-term CMS payment reductions and competitive penalties for not participating. 4. Recognize That Ambulatory MU-Incentive Payments Are Physician-Based. Because radiologists typically staff multiple locations of service, one must implement technologies and workflows that collect, aggregate, and act on information at each place (or places) where each physician encounters more than 50% of his or her patients. The requirement for multisite availability strongly favors a web-based solution. 5. Create a Plan That Can Evolve With MU Regulations. Over time, MU regulations can be expected to evolve. Therefore, one must implement a solution that can rapidly evolve independently of any existing radiology information system, hospital information system, or PACS, where rollout of new versions may take months or years. This logical pillar also points toward cloud-based solutions that can be upgraded with far greater agility. 6. Recognize That Work Flows Differ Between Radiology Departments and Imaging Centers. Ambulatory imaging patients are frequently seen in high volume with short examinations, such as a patient undergoing an outpatient chest radiograph. The radiologist often does not directly see the patient. Therefore, in a radiology setting, the ideal technology should do the following: 8 SPRING

5 Simply stated, your MU implementation should serve the spirit and detail of the law and the specific needs and dreams of imaging specialists. Murray A. Reicher or any referrer without requiring paperwork each visit can benefit patient care tients and referring doctors ing of medical imaging and the role of the radiologist. Simply stated, your MU implementation should serve the spirit and detail of the law and the specific needs and dreams of imaging specialists. 7. Understand That the Regulations Require the Adoption of Both Technologies and Work Flows. The technological solutions must encompass all of the specifications regulated by the Office of the National Coordinator for ambulatory MU compliance. A provider can achieve technological compliance by implementing a complete certified ambulatory EHR or by using a combination of certified modules that together comprise a complete ambulatory EHR. In addition, CMS separately regulates the clinical objectives that must be achieved. Thus, eligible providers must attest to both the implementation of the proper certified technologies and compliance with the following core clinical objectives: 10 menu-set objectives starts Stage 1): Meet each of the 17 core objectives and three of the six menu-set objectives. MU provides an opportunity to obtain federal funding to implement technologies of vital strategic importance to radiologists. Now is the time to realize that even if you are planning to opt out of the incentive payments, you cannot opt out of the reality that the EHR incentive program has already resulted in an irreversible revolution in health information technology. Even though radiologists have been leaders in the use of technology, we lag behind our clinical colleagues in adopting the required MU technologies, standards, and work flows. Create a Meaningful Use Action Plan for Get Involved Now. If you are a radiology professional who staffs a hospital or imaging center where you do not control the information technology, do not allow yourself to be a victim. Get involved now. It is your future. 2. Phone a Friend. While perhaps fewer than 3% of radiologists qualified for their incentive payments in 2012, some did have success and some visionaries even implemented systems that will provide a sustainable strategic advantage for their practice. Find and follow these leaders. 3. Get Staff Members on Board. Set aside a few hours for a radiology MU retreat and include all the key leaders needed to achieve success. 4. Get Started Early. There is an old saying, When you are early, you are on time, and when you are just on time, you are late. The best way to guarantee your success by the next deadline, October 1, 2013, is to succeed before then. SPRING