Home > EHR, meaningful use, Medicare > Meaningful Use Rule Update: Five Things Radiologists Should Know

Meaningful Use Rule Update: Five Things Radiologists Should Know

The Centers for Medicare and Medicaid Services (CMS) recently released its final rule to implement Stage 3 Meaningful Use (MU) participation requirements as well as changes to the existing MU requirements in 2015, 2016, and 2017.

Here are five things radiologists should know about the final rule…

1. Radiologists will continue to avoid payment adjustments as before

The final rule did not modify or eliminate the original significant hardship exception options. Diagnostic radiologists, nuclear medicine physicians, and interventional radiologists will continue to automatically obtain hardship exceptions based on PECOS specialty code on an annual basis for up to 5 total years. This will likely remain true until the future Merit-based Incentive Payment System (MIPS) assumes control over the financial implications of the Medicare incentive programs in 2019.

2. Stage 3 MU will be far less burdensome for participating radiologists than any previous stage

Radiologists without office visits will likely meet the exclusions of all but 3 or 4 of the Stage 3 objectives/measures. The remaining objectives/measures involve:

  1. protecting patient data,
  2. enabling five distinct clinical decision support (CDS) interventions/rules,
  3. incorporating and reconciling certain summary of care record (C-CDA) data into CEHRT, and,
  4. actively engaging with three registries.

Some radiologists may be able to be excluded from the third one above, depending on certain factors.

Beyond completing the MU objectives/measures, participants will need to report clinical quality measures (CQMs) and have certified EHR technology (CEHRT) “equipped” (accessed remotely, brought it on mobile device, or installed) at a location or combination of locations in which they have >50% patient encounters. The CQMs and CQM reporting options will be determined in future payment rules.

Stage 3 will be optional with a ninety-day reporting period in 2017 and mandatory with yearlong reporting periods in 2018 and beyond.

3. Modified Stage 2 in 2015, 2016, and 2017 is an improvement over the previous Stage 1 and Stage 2 requirements, but not as flexible as Stage 3 for radiologists

For ninety-day reporting periods in 2015, and full-year reporting periods in 2016 and (optionally) 2017, MU participants will be in “modified Stage 2.” Modified Stage 2 is essentially a slimmed down and consolidated version of Stage 2 MU objectives/measures. These modifications do not alter the currently acceptable CQMs or CQM reporting options.

All MU participants in modified Stage 2, including those who were scheduled to be in Stage 1, need to complete a smaller set of Stage 2 MU objectives. Participants slated for Stage 1 (i.e., first or second-year participants) can use certain Stage 1 thresholds in 2015. Those participants also have new “alternate exclusions” available to them. Based on 2014 participation statistics, and because of the hardship exception removing any incentive to start participating for the first time in 2015, I believe fewer than 200 diagnostic radiologists would have been in Stage 1 in 2015.

Diagnostic radiologists who were scheduled to be in Stage 2 in 2015 and 2016—i.e., most radiologist MU participants—would likely need to complete the measures of up to 5 total MU objectives related to:

  1. protecting patient data,
  2. enabling five distinct clinical decision support (CDS) interventions/rules,
  3. medication reconciliation,
  4. providing patients with the ability to view/download/transmit data, and at least 1 patient has done so (in 2015 and 2016), and
  5. actively engaging with two registries.

It is possible for some radiologists to meet the various measure exclusions needed to avoid the fifth objective above. Depending on interpretation, it may be possible for some radiologists to exclude from the fourth as well.

4. The “imaging results access” objective was eliminated from MU

There are pros and cons to the elimination of the referring physician-focused Stage 2 objective/measure to make imaging results accessible via CEHRT. While images and accompanying data continue to be critical to the patient’s record, many radiology practices were concerned that the MU regulatory requirement was sometimes misused by certain EHR vendors and hospitals/systems to misinform and discourage ordering physicians from referring their patients to unaffiliated imaging providers.

In the end, this and other previous Stage 2 MU objectives were eliminated by CMS from the modified Stage 2 MU requirements as part of the agency’s effort to simplify and consolidate MU in 2015, 2016, and 2017. Image-sharing and connectivity with referring physicians will continue to be important for patient care, customer service, and the future of radiology—it simply will no longer be part of the MU regulatory requirements for referring physicians.

5. Pay close attention to next year’s MIPS rulemaking

Ultimately, whether radiologists participate in Stage 3 MU will depend entirely on the outcome of the MIPS rulemaking in 2016. MIPS will serve as a likely less-preferred alternative to Alternative Payment Models (APMs) in 2019 and beyond. The MIPS concept effectively repackages and revamps the financial implications of the three current CMS quality incentive programs into an umbrella carrot-and-stick program based on a composite score comprised of various performance categories. MU participation would make up 25% of the composite score.

The MIPS/APMs-establishing legislation also directed CMS to explore potential alternatives to portions of the MIPS composite score for “non-patient-facing professionals.” It is possible that CMS could provide alternative pathways, elimination and re-weighting, or even a 1:1 substitute for MU’s portion of the MIPS composite score for non-patient-facing radiologists.

Time will tell if such alternatives to MU will be provided, and if the alternatives will be more attractive than Stage 3 MU. The answers to these questions, more than anything in this week’s final rule, will drive or deter Stage 3 MU participation by radiologists in the future MIPS era.

Questions about MU?  Please contact Michael Peters, ACR Director of Regulatory and Legislative Affairs, at mpeters@acr.org or 202-223-1670.

Categories: EHR, meaningful use, Medicare

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