Archive for March, 2014

Meaningful Use Significant Hardship Exception for Radiologists Clarified

March 20, 2014 6 comments

Radiologists often inquire about the significant hardship exception available to certain specialists as temporary reprieve from the payment adjustments for nonparticipation in the Medicare/Medicaid EHR Incentive Program (“Meaningful Use”). The most common question—is this automatically granted, or do I need to complete some sort of action?

As a quick background, one of the available exceptions is for physicians whose primary specialty codes in the Provider Enrollment, Chain and Ownership System (PECOS) are diagnostic radiology (30), nuclear medicine (36), or interventional radiology (94) (also anesthesiology and pathology). While the Centers for Medicare and Medicaid Services (CMS) suggested in public meetings that this particular option will be automatically granted, official written guidance from the agency lacked clarification about whether or not it will be fully and truly automatic (i.e., no further manual action required by the radiologist to obtain it).

That ambiguity has been addressed. Newly revised and enhanced guidance materials from CMS state:

Specialties – If you are classified in the Medicare Provider Enrollment, Chain and Ownership System (PECOS) as having one of the following 5 specialty codes as your primary area of practice you DO NOT need to submit this form. You will be granted a Hardship Exception and are automatically exempt from the 2015 payment adjustment based on the data in PECOS.

  • Diagnostic Radiology (30)
  • Nuclear Medicine (36)
  • Interventional Radiology (94)
  • Anesthesiology(05)
  • Pathology (22)

Therefore, if radiologists’ primary specialty code in PECOS is 30, 36, or 94 prior to the middle of this year, they will be automatically granted the exception for CY 2015 based on their PECOS data without having to fill out additional forms. Anyone planning to take advantage of this option should double-check their PECOS data before the month of July 2014 to make sure their primary specialty code is correct.

For information about other ways to avoid Meaningful Use payment adjustments, please read this article.

Categories: EHR, meaningful use, Medicare

HIT Policy Committee Meets, Approves Recommendations for Stage 3 Meaningful Use

March 13, 2014 Leave a comment

On March 11, the HIT Policy Committee (HITPC) of the Office of the National Coordinator for HIT (ONC) approved the Meaningful Use (MU) Workgroup’s recommendations for Stage 3. Several members of the HITPC shared concerns about aspects of the recommendations and whether or not the suggested approach would be the best approach. One member questioned the representativeness of the MU Workgroup and expressed the need for more practitioners and vendors in that advisory body.

Ultimately, the workgroup’s recommendations were approved as expected and will soon move up to the ONC and the Centers for Medicare and Medicaid Services (CMS) as those agencies begin drafting the future Notices of Proposed Rulemaking for Stage 3 MU and the 2017 Edition EHR Certification Criteria. The ONC and CMS staff are free to use, or not use, the recommendations however they wish.

The HITPC-approved recommendation for the Stage 3 iteration of the “clinical decision support” objective includes imaging (and lab-test) order appropriateness alongside a handful other priority areas for CDS interventions. The HITPC-approved recommendations do not offer a Stage 3 iteration of the Stage 2 objective for “imaging results access.” Likewise, the recommendations do not include sharing imaging data as part of the suggested Stage 3 “patient view/download/transmit” (patient portal) objective. Unfortunately, the recommendations do not include any mention of increased flexibility, alternative compliance pathways, or major regulatory framework changes to reduce the burden of MU compliance for specialists. As always, the American College of Radiology will work to educate the regulatory agencies.

At the same HITPC meeting, CMS staff announced a new guidance that will allow prior MU participants and new participants to obtain a significant hardship exception for the inability to implement 2014 Edition certified products in time. The announcement was important for any physicians unable to take advantage of the other available significant hardship exception options.  Most radiologists are already covered by the other options.

Categories: EHR, meaningful use, Medicare

ONC HITSC Standards Task Force Begins to Explore Technical Feasibility of HITPC Meaningful Use Workgroup’s Recommendations

March 7, 2014 1 comment

The newly formed Standards Task Force of the HIT Standards Committee (HITSC) held its first meeting on March 7 to gear up for future discussions on the technical feasibility of the HIT Policy Committee (HITPC) Meaningful Use (MU) Workgroup’s Stage 3 recommendations. The task force will examine the Stage 3 MU advice from a “standards maturity” (immature, emerging, approved, or adopted) and “development effort” (low, med, or high) point of view.

The full HITPC is expected to approve the MU Workgroup’s recommendations at its monthly meeting on March 11. The HITSC’s Standards Task Force will then convene discussions on March 17 and March 24 to organize and refine opinions on technical feasibility. The finalized findings will be presented to the full HITSC on March 26.

After reviewing the HITPC’s Stage 3 MU recommendations, the task force will shift its focus over to proposals in the Office of the National Coordinator for HIT’s (ONC) 2015 Edition EHR Certification Criteria proposed rule.

Categories: EHR, meaningful use, Medicare

Meaningful Use Workgroup Prepares to Present Stage 3 MU Recommendations to Full HIT Policy Committee for Approval

March 6, 2014 2 comments

The HIT Policy Committee (HITPC) Meaningful Use (MU) Workgroup held its final public discussion on March 4 in preparation for next week’s full HITPC meeting when the workgroup’s Stage 3 MU recommendations will be presented and likely approved. Following HITPC approval, the recommendations will go to the HHS Office of the National Coordinator for HIT (ONC) and Centers for Medicare and Medicaid Services (CMS) to inform the future Stage 3 MU and 2017 Edition EHR Certification Criteria rulemakings.

Importantly, CMS and ONC staff are free to use or not use the HITPC recommendations however they wish as they work on proposed rules over the next several months. CMS and ONC hope to publish the Notices of Proposed Rulemaking on Stage 3 MU and the 2017 Edition around Fall 2014 for public comment, with final rules promulgated around mid-2015.

In terms of imaging-related subtopics, the MU Workgroup will likely recommend discontinuing the “imaging results access” objective in Stage 3 MU. The workgroup’s expressed goal for this change was to reduce participants’ reporting burden (i.e., the total number of MU objectives recommended for Stage 3 Meaningful EHR Users). Also, the MU Workgroup is not explicitly recommending the inclusion of imaging data in the “patient view, download, transmit” (or “patient portal”) objective despite the recent work of the HIT Standards Committee’s Clinical Operations Workgroup. Finally, the MU Workgroup continues to recommend that one of the main priority areas for CDS rules/interventions be radiology and lab-test appropriateness.

Categories: EHR, meaningful use, Medicare