MU Educational Session at RSNA 2015

In this month’s post, we take a look at an upcoming educational session at RSNA 2015.

In less than 2 weeks, nearly 60,000 radiology professionals from around the world will converge on Chicago to witness the latest discoveries, techniques and innovations for diagnostic imaging.

If you’re heading to the windy city later this month, don’t miss this educational session dedicated to meaningful use in radiology.

Meaningful Use for Radiology: Pros and Cons
Tuesday 8:30-10:00 AM | RC354 | S404CD

AMA PRA Category 1 Credits™: 1.50 | ARRT Category A+ Credits: 1.50

Presenters:

  • Ramin Khorasani, MD (Moderator/Presenter)
  • Alberto F. Goldszal, PhD, MBA (Presenter)
  • Keith D. Hentel, MD, MS (Presenter)
  • James Whitfill, MD (Presenter)

Learning Objectives:

  • Understand how a radiology practice that was a later adopter of meeting meaningful use criteria has achieved successful results for two years running.
  • Learn about CMS MU audits and the audit process.
  • Learn about challenges for meaningful use stage 2 and radiology.

Find more educational sessions on RSNA.org »

Ready to learn more, buy a book today! 

Go to http://www.theMUguide.com to learn more. Buy a book from the official e-store (http://buy.theMUguide.com) or Amazon.com (http://amazon.theMUguide.com).

OMB Reviewing Final Rules to Update Meaningful Use and HIT Certification Criteria

In this month’s post, we take a look at an article posted on Radiology and HIT Blog on September 11, 2015 which discusses the next round of final rules which are currently under review.

Earlier this month, the HHS Office of the National Coordinator for HIT (ONC) and Centers for Medicare and Medicaid Services (CMS) submitted final rules to update the EHR Incentive Program participation and technology certification requirements for White House Office of Management and Budget (OMB) regulatory review. OMB regulatory review is one of the final closed steps prior to public release, and the process typically takes 30 to 90 days.

There are two CMS final rules (2015-2017 and Stage 3) and one ONC final rule (2015 Edition HIT certification criteria) under review. We should expect at least the main final rule on meaningful use (MU) modifications for 2015-2017 to be published before October to enable 90-day reporting periods to commence on October 1. The Stage 3 final rule also includes “modifications for 2015-2017” in the title, which could mean pieces of the MU fix are divided between some sort of expedited “modifications” final rule and a lengthier “Stage 3” final rule to be published later. However, it is equally possible that all three CMS and ONC final rules will be published simultaneously given that all three were submitted for OMB review on the same September 3 date.

Read more on RadiologyandHealthIT.com.

Ready to learn more, buy a book today! 

Go to http://www.theMUguide.com to learn more. Buy a book from the official e-store (http://buy.theMUguide.com) or Amazon.com (http://amazon.theMUguide.com).

Flex-IT 2 Act Provides Relief to Physicians, Hospitals and Healthcare Providers Facing Tough Health IT Mandates

In this months post, we take a look at a recent post on www.house.gov on July 30, 2015 that introduces legislation that would delay CMS promulgation of the Stage 3 MU Final Rule and mandate a 90-day EHR reporting period every year, among other updates.

Congresswoman Renee Ellmers (R-NC-02) introduced H.R. 3309 – the Further Flexibility in HIT Reporting and Advancing Interoperability Act or Flex-IT 2 Act on July 30, 2015.

According to the post, there continues to be a need for healthcare providers to have flexibility in meeting CMS’ rigid deadlines: only 19 percent of providers and 48 percent of hospitals have met Stage 2 of the Meaningful Use. To address mounting concerns among healthcare providers, Rep. Ellmers has introduced the Flex-IT 2 Act to address concerns with CMS’ proposed rules for Meaningful Use Stage 3 rules for the Medicare and Medicaid EHRs Incentive Programs.

This robust legislation encompasses 5 measures:

(1) Delay Stage 3 Rulemaking until at least 2017, or MIPS final rules or at least 75 percent of doctors and hospitals are successful in meeting Stage 2 requirements.
(2) Harmonize reporting requirements (MU, PQRS, IQR) to remove duplicative measurement and streamline requirements from CMS.
(3) Institutes a 90-day reporting period for each year, regardless of stage or program experience
(4) Encourages interoperability among EHR systems
(5) Expands hardship exemptions, as they are very narrowly defined under current regulations

View H.R. 3309 – the Further Flexibility in HIT Reporting and Advancing Interoperability Act (Flex-IT 2 Act): click here.

Ready to learn more, buy a book today! 

Go to http://www.theMUguide.com to learn more. Buy a book from the official e-store (http://buy.theMUguide.com) or Amazon.com (http://amazon.theMUguide.com).

National Physician Associations Share Meaningful Use Concerns

In this months post, we take a look at a recent article posted on Radiology and HIT Blog that discusses concerns shared during a meeting of national specialty societies regarding the future of the Medicare/Medicaid EHR Incentive Program on June 24, 2015.

The American College of Radiology (ACR) government relations staff participated in an American Medical Association (AMA)-hosted meeting of the national specialty societies regarding the future of the Medicare/Medicaid EHR Incentive Program on June 24, 2015.

Regulatory affairs staff from approximately 25-30 different national specialty societies participated in the discussions, and all presented their members’ concerns regarding the Centers for Medicare and Medicaid Services’ (CMS) and Office of the National Coordinator for Health IT’s (ONC) ongoing rulemakings to update the program’s requirements.

Noteworthy from the meeting was that all national physician associations continue to share many of the same concerns about the current status and future outlook of the program. While some specialists have unique challenges, the shared concerns include:

  • Alarmingly low participation levels
  • Overly optimistic agency outlook and timetables for the program
  • Health IT certification expansion beyond Meaningful Use (MU) applications
  • Yearlong reporting periods for all participants in 2018 and beyond
  • Lack of full alignment between PQRS and MU’s clinical quality measure reporting
  • Relevance of requirements to workflow/scope of practice
  • Uncertain future MIPS implementation hanging over the current pre-MIPS MU rulemakings
  • And more…

Read more on the Radiology and HIT Blog.

Ready to learn more, buy a book today! 

Go to http://www.theMUguide.com to learn more. Buy a book from the official e-store (http://buy.theMUguide.com) or Amazon.com (http://amazon.theMUguide.com).

eCQM Updates for 2016 Reporting Now Available in the eCQI Resource Center

In this months post, we take a look at eCQM Updates for 2016 Reporting and newly published resources.

Each year, CMS makes updates to the electronic specifications of the Clinical Quality Measures approved for submission in CMS programs.

CMS strongly encourages the implementation and use of the updates to the electronic specifications of the CQMs finalized in the Stage 2 rule for the 2015 EHR Reporting Period since those updates include new codes, logic corrections and clarifications.

Below are updates published in May 2015:

eCQMs for Eligible Professionals Table (Update: May 2015): This table contains additional up-to-date information for the EP clinical quality measures finalized in the Medicare and Medicaid Programs; Electronic Health Record Incentive Program; Final Rule. Download the EP Measures Table »

eCQM Specifications for Eligible Professionals (Update: May 2015): Download the specification documentation »

eCQM Measure Logic Guidance v1.10 (Update: May 2015): This guidance document is for use with the updated Eligible Hospital and Eligible Professional measure specifications released on May1, 2015 for the 2014 Eligible Professional and Eligible Hospital electronic Clinical Quality Measures (eCQMs) released on December 21, 2012. Download the eCQM Logic and Implementation Guidance »

eCQM Technical Release Notes (Update: May 2015): Download technical release notes »

Read more on CMS.gov »

Ready to learn more, buy a book today! 

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CMS Staff Clarify Scope of the Meaningful Use ‘Medications Reconciliation’ Denominator

In this months post, we take a look at a recent article posted on Radiology and HIT Blog discusses recent clarification .

The Centers for Medicare and Medicaid Services (CMS) staff informed the American College of Radiology (ACR) that the denominator for the current “medications reconciliation” Stage 1 and Stage 2 Meaningful Use measure can be limited to the subset of patients that comprise the physician’s “seen” definition.

In the explanatory preamble of CMS’ September 2012 Stage 2 MU rule, the agency clarified: “for an EP who is on the receiving end of a transition of care or referral, (currently used for the medication reconciliation objective and measure), the denominator includes first encounters with a new patient and encounters with existing patients where a summary of care record (of any type) is provided to the receiving provider.” This was a major change from the 2010 Stage 1 MU rule which clearly distinguished the term “transitions of care” from “referrals” in which the referring provider maintained management of the patient. Ultimately, the 2012 clarification meant that referral-based care was to be included in the “medications reconciliation” objective/measure moving forward.

Many MU participating radiologists have used the “seen patients” flexibility to appropriately reduce their denominators for applicable objectives to more manageable numbers. Previously, “medications reconciliation” was not thought of as being an applicable objective because the denominator of “received transitions of care” does not refer to “patients seen by the EP.” So, whereas a radiologist could have been meeting other percentage-based MU measures on a smaller subset of their overall patient volume, they would have needed to use their full patient volume for the “medications reconciliation” measure under the 2012 clarification.

Read more on the Radiology and HIT Blog.

Ready to learn more, buy a book today! 

Go to http://www.theMUguide.com to learn more. Buy a book from the official e-store (http://buy.theMUguide.com) or Amazon.com (http://amazon.theMUguide.com).

The last mile of meaningful use — value

In this months post, we take a look at an article written by, Bob Cooke, Vice President, Marketing, National Decision Support Company.

The Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator (ONC) for Health IT took a leap forward with their recent releases of the Stage 3 Proposed Rule and HIT certification criteria, respectively. At the highest level, a key requirement derived from these proposed program updates is that providers will need to comply with a revised set of requirements in order to receive future value-based reimbursements.

The Stage 3 Proposed Rule focuses on the exchange of data across episodes of care as opposed to whether or not providers “see patients,” “have office visits,” or fall under others terms that don’t really apply to radiologists. It’s not that radiologists don’t conduct “office visits,” or “see patients,” it’s just that to apply these definitions against a radiologist’s compliance with Meaningful Use, and more importantly, extracting value from participation by imaging is practically impossible. Collecting this data is not enough for radiology.

Take smoking status for example, a fairly simple piece of data. For most of the radiologists in the country, this simple piece of data is not available as part of the interpretation process. Collecting it when you see a patient is one thing, but for a radiologist to see it when they interpret an exam for the patient, it can mean everything, as Brigham and Women’s Hospital found out when a jury awarded a patient $16.7 million for a missed cancer diagnosis on a simple CXR for a patient. It turns out the radiologist did not have access to the patients history, which included a family history of lung cancer and a 30 year habit. The exchange of this kind of data is critical to healthcare providers and consumers alike.

Exchanging data across episodes of care (e.g. a radiology encounter) has tremendous benefits to radiology as it enables practices to capture relevant clinical information and apply it towards value-based workflows using widely available, and established, implementation standards. Furthermore, this same exchange mechanism transports coded radiology results, updated medications (for interventional exams) and vitals as appropriate, as the Stage 3 Proposed Rule formally defines the radiology report as part of the Clinical Document Architecture (CDA).

Another key component of Meaningful Use is Clinical Decision Support (CDS). And, the Stage 3 Proposed Rule encompasses the implementation of CDS for recording clinical quality measures and to align incentives with the Physician Quality Reporting System (PQRS). Furthermore, the Protecting Access to Medicare Act of 2014 (PAMA) requires physicians to consult CDS in order to receive payments for Medicare claims.

All in all, radiology has an opportunity to leverage these proposed program updates to deeply embed themselves into the patient care cycle and measure and improve their value in delivering more cost effective and higher quality patient care.

Ready to learn more, buy a book today! 

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How to Avoid Meaningful Use Penalties in 2016

In this months post, we take a look at a recent article posted on Radiology and HIT Blog discusses two ways to avoid MU penalties coming next year.

The negative payment adjustments for non-participation in the Medicare EHR Incentive Program (“Meaningful Use” or MU) will increase to -2% off covered professional services in calendar year (CY) 2016. Physicians who are eligible for the Medicare version of the program will have two ways to avoid the 2016 penalties:

Option 1: Compliance

  • Prior MU participants must have been a Meaningful EHR User in 2014 to avoid the 2016 penalties. If the prior MU participant was not MU-compliant in 2014, he/she must use Option 2 below.
  • Those who have never participated in MU must begin participating by July 1, 2015 and complete the attestation process by October 1, 2015 (at the latest) to avoid 2016 penalties. If the first-time participant does not meet the attestation deadline, he/she must use Option 2 below.

Option 2: Significant hardship exception

Regardless of whether or not a physician was MU compliant in the past, he/she can obtain one of several “significant hardship exceptions” to avoid 2016 penalties. CMS can grant these to physicians on an annual basis for up to 5 total years. The various available significant hardship exceptions are as follows:

  • Lacking broadband/infrastructure
  • Newly practicing
  • Extreme and uncontrollable circumstances
  • Inability to influence availability of certified EHR technology (CEHRT)
  • Lack of face-to-face/telemedicine interaction with patients AND lack of need for follow-up
  • Primary specialty listing in PECOS

Read more on the Radiology and HIT Blog.

Ready to learn more, buy a book today! 

Go to http://www.theMUguide.com to learn more. Buy a book from the official e-store (http://buy.theMUguide.com) or Amazon.com (http://amazon.theMUguide.com).

CMS Announces Intent to Engage in Rulemaking for EHR Incentive Program Changes for 2015

In this month’s post, we take a look at a recent CMS blog post that discusses the organization’s intent to modify requirements for Meaningful Use.

The Centers for Medicare & Medicaid Services (CMS) intends to engage in rulemaking this spring to help ensure providers continue to meet meaningful use requirements. In response to input from health care providers and other stakeholders, CMS is considering the following changes to the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs:

  • Shortening the 2015 reporting period to 90 days to address provider concerns about their ability to fully deploy 2014 Edition software
  • Realigning hospital reporting periods to the calendar year to allow eligible hospitals more time to incorporate 2014 Edition software into their workflows and to better align with other quality programs
  • Modifying other aspects of the programs to match long-term goals, reduce complexity, and lessen providers’ reporting burden

These proposed changes reflect the Department of Health and Human Services’ commitment to creating a health information technology infrastructure that (1) elevates patient-centered care, (2) improves health outcomes, and (3) supports the providers who care for patients.

While CMS intends to pursue these changes through rulemaking, they will not be included in the pending Stage 3 proposed rule. CMS intends to limit the scope of the pending proposed rule to Stage 3 and meaningful use in 2017 and beyond.

Read more about this announcement on the CMS blog.

Ready to learn more, buy a book today! 

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White House Reviewing CMS and ONC Proposed Rules to Update the EHR Incentive Program and HIT Certification Requirements

In this month’s post, we take a look at a recent post on the Radiology and Health IT Blog.

An article posted on Radiology and HIT Blog discusses important updates to the EHR Incentive Program and certification requirements.

The HHS Office of the National Coordinator for HIT (ONC) and Centers for Medicare and Medicaid Services (CMS) submitted proposed rules to update the EHR Incentive Program participation and technology certification requirements for White House Office of Management and Budget (OMB) Office of Information and Regulatory Affairs (OIRA) review. OIRA review is one of the final steps in the federal rulemaking process prior to submission to the Government Publishing Office’s (GPO) Office of the Federal Register (OFR). Public stakeholders will be able to access the text of these two Notices of Proposed Rulemaking (NPRMs) for the first time when they are placed on the OFR’s Public Inspection Desk. So, while we know that public release of the NPRMs is imminent (OIRA review could last up to 90 days – usually closer to a month or two), the only information we have about the content at the moment is included in the rough descriptions on OIRA’s website.

The description for CMS’ NRPM, “Electronic Health Record (EHR) Incentive Programs–Stage 3” (RIN: 0938-AS26), indicates that it will propose changes to “the reporting period, timelines, and structure of the program, including providing a single definition of meaningful use.” It goes on to say that “These changes will provide a flexible, yet, clearer framework to ensure future sustainability of the EHR program and reduce confusion stemming from multiple stage requirements.” Hopefully, this means physician participants will be rewarded with a new, much-needed infusion of flexibility this rulemaking cycle.

Read entire article on Radiology and HIT Blog

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