Regional Medical Imaging (RMI) recognized early that their organization should understand the impact of Meaningful Use (MU). The practice provides radiology services in five locations across mid-Michigan. Realizing that its providers are eligible for $600,000 in incentives, the practice decided to proactively address its approach to optimize the MU opportunity.
RMI is not the typical practice. In fact, the majority of radiology practices have been delayed in developing a deep understanding of the risks and rewards associated with MU. Some diagnostic imaging providers are unaware they will see declining reimbursements when MU penalties are imposed in 2015.
In the imaging community, most early responses to the American Recovery and Reinvestment Act of 2009 (ARRA) focused on the “exclusion” of radiology from MU or specialty-specific pathways within MU. A shift happened in 2010, however, when legislators changed the definition of an “eligible professional (EP).” At this time, the vast majority of radiologists joined primary care physicians in meeting the definition of an EP. Soon thereafter, the diagnostic imaging community realized it stood to gain up to a billion dollars in stimulus funds and would be subject to reductions in reimbursements starting in 2015.
Today, as some radiology practices move aggressively ahead with their MU strategy, others remain unclear about MU. They lack understanding of the operational and technology decisions that may soon be bearing down upon them.
The following Q&A offers an overview of MU to assist radiology practices.
What is meaningful use?
MU is broad terminology that refers to a government-sponsored initiative that has been designed to encourage providers to use healthcare IT solutions to improve the quality of care while lowering costs. The initiative rewards providers who use a certified electronic health record (EHR) solution in a meaningful way.
The HITECH provisions of the ARRA define the specific legislative action that provides significant financial incentives to assist providers in the purchase, implementation, and meaningful use of a certified EHR system.
Who is eligible to receive stimulus dollars under ARRA/HITECH?
The ARRA outlines two separate EHR incentive programs: a Medicare program and a Medicaid program. Each has its own set of eligibility requirements. EPs may participate in only one. In each case, EHR incentive payments will be available for EPs that demonstrate meaningful use of an EHR.
The Medicaid program provides for up to $63,750 in incentives per EP meeting MU criteria. EPs in the Medicaid program must be physicians, nurse practitioners, certified nurse-midwives, dentists, or physician assistants that meet one of the following criteria:
* Practice predominantly in a federally qualified health center or rural health center and have a minimum of 30 percent patient volume attributable to needy individuals
* Have more than 30 percent of patients paying with Medicaid (more than 20 percent for pediatricians) for 90 continuous days in the year prior to eligibility.
The Medicare program provides for up to $44,000 in incentives per EP that meets MU criteria and accepts Medicare payments. EPs in the Medicare program must be doctors of medicine, osteopathy, dental surgery, dental medicine, podiatry, optometry, or chiropractors.
Hospital-based EPs are not eligible for incentive payments. An EP is considered hospital-based if 90 percent or more of his or her services are performed in a hospital inpatient or emergency room setting.
Research shows that up to 90 percent of radiologists qualify as eligible providers for MU due to the fact that hospital outpatient work is excluded from the definition of a hospital-based EP. However, the determination of eligibility can be somewhat complicated. Radiology practices are encouraged to assess eligibility through online tools such as www.radmu.org.
How many times can a physician qualify for MU?
Each EP is only eligible for one incentive payment per year, regardless of how many practices or locations at which he or she provides services.
What are the requirements for MU?
Purchasing an EHR does not, on its own, qualify a provider to receive stimulus dollars. A provider must actually make “meaningful use” of this technology.
There are four fundamental requirements for MU:
* Determine EP eligibility and either the Medicare or Medicaid program
* Connect certified EHR technology in a manner that provides for the electronic exchange of health information to improve the quality of care
* Use certified EHR technology in a meaningful manner
* Submit information on clinical quality measures and other measures to the CMS.
What is certified EHR technology?
The government has defined a set of core functionality that must be present in health care IT applications in order to be considered compliant. If an EHR has that set of functionality, it can be validated by a certified testing group that can give EHR solutions the “stamp of approval” for certification. There are two types of certification: complete EHR certification and modular EHR certification. Complete EHR certification means that the EHR has met all functional requirements whereas modular EHR certification means that the EHR has only met a subset of the functional requirements.
It is important to note that EPs must implement technology that meets all of the requirements set forth by the Office of the National Coordinator even if the EP ultimately does not use all of the functionality. Therefore, an EP that uses an EHR with modular certification would need to ensure that multiple technology packages are implemented to cover all functional requirements.
Are vendors certifying their solutions for MU?
Many vendors offering traditional EHR systems for primary care physicians are well under way with certifying their solutions. Some vendors offering specialty systems are evaluating MU functional requirements relative to the capabilities of their products, including those offering RIS and other specialty information management solutions (i.e., orthopedics, cardiology, perioperative, etc.). Merge Healthcare, for example, announced certification of its OrthoEMR 4.0 in August 2011 and will plan for certification of Merge RIS in 2011 through the Drummond Group. The Drummond Group is an Office of the National Coordinator Authorized Testing and Certification Body.
How does a practice use EHR technology in a meaningful manner?
There are a total of 25 MU objectives. To qualify for an incentive payment, 20 of these 25 objectives must be met. Of the 25 objectives, 15 are required core objectives and the remaining five objectives may be chosen from a list of 10 menu set objectives.
Radiologists are not intuitive users of some of the objectives and would have no ability to report results. Therefore, exemptions are allowed for some. For example, a radiologist who writes less than 100 prescriptions a year would be exempt from the e-prescribing measures. It is important for each individual radiologist to understand how he or she will meet each objective. The complete list can be found at: https://www.cms.gov/EHRIncentivePrograms/Downloads/EP-MU-TOC.pdf.
How does a practice submit information to CMS?
In April 2011, the CMS started accepting data via its attestation system on https://ehrincentives.cms.gov/. The system requires EPs to complete sections on these topics:
* Meaningful Use Core Measures
* Meaningful Use Menu Measures
* Core Clinical Quality Measures
* Alternate Core Clinical Quality Measures (only required if any core CQM has a denominator of zero)
* Additional Clinical Quality Measures
When will EHR stimulus funding actually come to eligible providers, and in what form?
A consolidated incentive payment will be made on a rolling basis as soon as CMS ascertains that a provider has demonstrated MU for the applicable reporting period. The reporting periods are 90 days for the first year and a calendar year for subsequent years. The following diagram illustrates how payments will be distributed based on the first year of qualification.
First Year of Qualification
What happens if a doctor chooses to not participate?
While participation in MU is not required by law, late adopters or non-adopters may lose thousands of dollars in incentives and, in 2015 or later, will see Medicare payment reductions of up to 5 percent.
Where can I find out more information about MU?
The CMS Web site www.cms.gov/EHRIncentivePrograms provides complete information on registration, attestation, and more, while http://www.radiologymu.org/ provides information specifically for radiologists, including tools, an eligibility analyzer, advocacy efforts, and more.
Meeting MU requirements doesn’t have to be a daunting exercise. Take the first step by assessing eligibility using the Meaningful Use Practice Analyzer found at http://www.healthmu.org/radiology/analyze/index.php. The application will help you determine your eligibility and practice-specific technical requirements, as well as understand the financial impact of the incentive programs. You will need the following information:
* Number of radiologists
* Total annual CMS revenue per radiologist
* MU data collection start date
* Percentage of CMS volume that is inpatient hospital
* Percentage of CMS volume that is emergency room
* Whether the group practices in an HPSA (health professional shortage area)
* The certified technologies you plan to use to achieve MU.
Key MU Dates
Jan. 3, 2011: Registration opens for the Medicare EHR Incentive Program. You do not need to have certified technology in place to register.
April 18, 2011: The attestation website for the Medicare program opens. EPs may begin submitting data.
Jan. 1, 2012: Reporting year begins for EPs.
Sept. 30, 2012: Certified software must be completely installed to begin data collection by Oct. 1 and meet 2012 deadlines.
Oct. 1, 2012: The start of the final 90-day reporting period for 2012. All providers wishing to qualify for MU for 2012 must begin collecting MU data by this date. Eligible providers who wait until the following year will not qualify for the full reimbursement.
Dec. 31, 2012: Reporting year ends for EPs. Ninety continuous days of data must be collected in 2011 by this date to qualify for a 2012 reimbursement.
Feb. 28, 2013: Final day to submit data to qualify for 2012 payments.
Steven Tolle is senior vice president of solutions management for Merge Healthcare.