Meaningful Use has been a bit of a mystery to radiology from the beginning. Initially, there was much debate as to whether Meaningful Use even applied to the radiologist. Meaningful Use was certainly designed with a one-size-fits-all approach, but whether it even fit radiology at all was another discussion. However, in April, 2010, with the release of the Continuing Extension Act of 2010, it became clear that most radiologists would be included as Eligible Professionals (EPs). But with this late clarification, many radiologists find themselves unprepared to meet Meaningful Use criteria.
The distinguishing factor in the Continuing Extension Act of 2010 is that the Outpatient Hospital category, which was originally considered to fall under an Eligible Hospital (EH), was clarified to be categorized under an EP. What this means is that unless your practice is over 90% inpatient and ER, you are considered an EP. The consequence of this is that most radiologists were immediately shifted from the umbrella of an EH to being considered an independent EP. This left many radiologists scrambling to understand the intricate details of Meaningful Use and how it applied to them. It also left many RIS vendors trying to understand modular EHR certification as well.
Even though radiologists might be late-to-the-game, they may have an easier path to execution than other practitioners. Meaningful Use is based on 15 core measures, and an additional 10 measures of which 5 can be opted out of. Of the 15 core measures, 6 are eligible of exclusion. And, of the 10 additional measures, 8 are eligible for exclusion. For example, one of the core measures is the requirement to use Computerized Physician Order Entry (CPOE). However, if an EP writes fewer than 100 prescriptions a reporting period then they can be excluded from this requirement. With many of the exclusions applying to radiologists, it could be feasible that a tele-radiologist might only have 10 measures that apply. And the measures that do apply would likely not have any direct impact of the work of the radiologist, but rather could be handled by the RIS or practice management systems that together meet the requirement of a certified EHR system.
While the hurdles to meet Meaningful Use may just seem like hoops to jump through for the radiologist, it is still important for radiologists to be involved. On July 12th at a Carestream event in Dallas, Dr. Keith Dreyer spoke on Meaningful Use in Radiology and a ten step approach (radiologyMU.org) for the radiologist to develop their strategy for achieving Meaningful Use.
Dr. Dreyer provided calmness around the tasks of executing such a strategy. He detailed many useful insights as to how a radiologist can realistically meet the requirements. But more importantly, he emphasized that radiologists should be involved, not only in satisfying Stage 1 requirements, but more importantly in lobbying for more appropriate requirements related to the radiologists for Stages 2 and 3. If better quality of care is the ultimate goal, then imaging needs to be a part of the criteria, with seamless interoperability of images being the ultimate criteria.
With the current definition of an EP, most radiologists are eligible for incentives and also penalties down the road. And even though most of the criteria for Meaningful Use Stage 1 is not clinically relevant to the radiologist, it is important that radiology get involved in meeting Stage 1 and having their voice heard for future stages. Meaningful Use Stage 1 defines very introductory criteria for sharing medical data and moving towards interoperability, but there needs to be much more with the inclusion of images in future stages. Ideally, IHE profiles including XDS, and more specifically XDS.i for imaging, would be included in the future stages. In the end, interoperability must include the images, and it begins now with radiologists being included in all stages of Meaningful Use.
Events such as the one hosted by Carestream recently are critical to fostering ideas, promoting the real message behind Meaningful Use, and setting the expectations for future criteria. The discussion that was shared was extremely valuable to all that attended, and thanks goes to Carestream for putting the event together.