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ACR Comments on Stage 3 Meaningful Use Final Rule

December 17, 2015 Leave a comment

On December 15, the American College of Radiology (ACR) submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding the Stage 3 EHR Incentive Program (Meaningful Use) final rule. ACR’s comments reiterated its prior recommendations to the agency on the Alternative Payment Models/Merit-based Incentive Payment System (MIPS) Request for Information from October as well as the Stage 3 MU Notice of Proposed Rulemaking from last March.

For the MU performance category in MIPS (worth 25 percent of the composite score), ACR recommended that “non-patient-facing professionals” be able to choose from three potential options: 1) Stage 3 MU as is, 2) exclusion and recalculation of the MIPS composite score using the remaining categories, or, 3) active engagement with relevant clinical data registries. Additionally, ACR recommended simplification and various other changes to the MU paradigm in the MIPS era (2019 and beyond) so that Stage 3 MU would not be an all-or-nothing, pass-or-fail chunk of the composite score.

ACR also focused on the clinical information incorporation and reconciliation measures of the “health information exchange (HIE)” objective—perhaps the most challenging and resource-intensive requirements of future Stage 3 MU compliance for diagnostic radiologist participants. Specifically, the College recommended that referrals for imaging services not be included in the “transitions of care/first time encounters with new patients” denominator for the second and third measures of the Stage 3 HIE objective. Several reasons were provided for this recommendation: 1) referring providers still rarely send C-CDA documents alongside imaging orders, so radiologists’ requests for the missing summary of care records (and, to a lesser degree, HIE network queries) as called for by MU requirements (prior to being able to exclude those referrals from the denominator) would be commonplace and time/resource-intensive; 2) physicians may not always have a clinical need for their referred patients’ medications, medication allergies, or problem list data (the minimum data from C-CDA documents that need to be incorporated and reconciled by ToC/referral recipients); and 3) radiologists should have the option to securely obtain, incorporate, and reconcile any clinically relevant patient data from referring providers—not be forced to double back and request C-CDA documents prior to excluding referrals from the denominator of measures 2 and 3 of the HIE objective, or to incorporate/reconcile potentially unhelpful data from any (rare) received summary of care records.

For questions regarding ACR’s comments or MU in general, please contact Michael Peters, ACR Director of Regulatory and Legislative Affairs, at mpeters@acr.org or 202-223-1670.

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Categories: EHR, meaningful use, Medicare