ACR Comments on ONC’s Proposed Rule to Establish Voluntary 2015 Edition EHR Certification Criteria

In this month’s post, we take a look at the ACR’s comments on the ONC’s Proposed Rule to establish voluntary 2015 Edition EHR Certification Criteria.

Last month, the American College of Radiology (ACR) submitted comments to the HHS Office of the National Coordinator for HIT (ONC) regarding the agency’s proposed rule to establish voluntary 2015 Edition EHR certification criteria. The 2015 Edition would be an optional alternative to the 2014 Edition criteria for the certification of products used by participants in the Medicare/Medicaid EHR Incentive Program (“meaningful use”). Additionally, the proposed rule included several questions intended to inform the ONC’s future 2017 Edition rulemaking.

he ONC’s two previous EHR certification criteria rulemakings took about 7 to 8 months between the publication dates of the proposed rules and final rules. While it is possible ONC could turn the 2015 Edition final rule around more quickly (perhaps even as early as August), it is unclear how the separate and conflicting 2017 Edition rulemaking will impact the timing.

Links to resources:

For more information, please visit the Radiology and HIT Blog.

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It’s 2014, time for Stage 2 MU (and some updates for Stage 1)

In this month’s post, we take a look at 2014, Stage 2 MU, and changes for Stage 1 MU. 

For the radiologists that have already completed two years of Stage 1 MU, 2014 will be the year Stage 2 MU begins. Stage 2 retains the same basic structure as MU Stage 1 and providers must report on 20 objectives (17 core objectives and 3 out of a possible 6 menu objectives) in Stage 2. The meaningful use measures are split into core and menu objectives—eligible professionals must report on all core objectives, but can choose the menu measures that pertain to their practice.

CMS and the ONC have established standards and certification criteria for structured data that EHRs must use in order to successfully capture and calculate objectives for Stage 2 of meaningful use. These new standards and certification criteria will take effect in 2014. EHR technology that is certified to the 2014 standards and certification criteria will allow providers to meet both Stage 1 and Stage 2 meaningful use requirements (for more information about certified EHRs and the new 2014 standards and certification criteria, please visit ONC’s new 2014 Certification Programs and Policy page:

For 2014 Only

Because all providers must upgrade or adopt newly certified EHRs in 2014, all providers regardless of their stage of meaningful use are only required to demonstrate meaningful use for a three-month (or 90-day) EHR reporting period in 2014: Medicare eligible professionals in their first year of meaningful use may select any 90-day reporting period. Medicaid eligible professionals can select any 90-day reporting period that falls within the 2014 calendar year.

Stage 2 MU Requirements

17 Core Objectives – These are objectives that everyone who participates in Stage 2 must meet. Some of the core objectives have exclusions, but many do not.

3 of 6 Menu Objectives – You only have to report on 3 out of the 6 available menu objectives for Stage 2. You can choose objectives that make sense for your workflow or practice. Again, some of these objectives have exclusions.

Many of the objectives in Stage 2 are similar to Stage 1. Some objectives that were in the menu set in Stage 1 have been moved to the core set for Stage 2 and are now required for all providers. Some objectives that were in the core set in Stage 1 now have higher thresholds that you must achieve in order to successfully demonstrate meaningful use of your EHR in Stage 2. There are also new Stage 2 core and menu objectives.

For more information about Stage 2 MU, visit http//

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MU in Action: Meaningful Use for Radiology

In this month’s post, we highlight an interview conducted with Dr. Wells Mangrum, MU program lead at a small radiology practice in Wisconsin.

Medical X-Ray Consultants is a small practice of 12 radiologists in Eau Claire Wisconsin that services a variety of hospitals across northwest Wisconsin and eastern Minnesota. As part of their commitment to quality, participating in the Meaningful Use program was an important part of their strategic plan.

What was the core challenge you faced in implementing a Meaningful Use program?

Our small radiology group covers many hospitals and each provider organization has a different Electronic Health Record (EHR). Many of these hospital EHRs are certified for Meaningful Use (MU) on the inpatient side, but not outpatient. Accordingly, our radiology group found ourselves in a dilemma as to how to meet MU requirements in the outpatient setting. We also needed to balance the workflow impact of leveraging all the various EHR solutions verses finding a more streamlined solution.

What solution did you find?

After exploring all available options, we found ImagingElements, a radiology-centric EHR provider that offers a complete certified solution to meet outpatient MU requirements. They offered a platform and capability that resolved our dilemma—we use their web-based platform to record outpatient information in a manner that satisfies Meaningful Use requirements. One of ImagingElements unique capabilities is their “denominator reduction” approach. This dramatically reduces our data collection workload and focuses our Meaningful Use efforts towards the specific encounters that matter.

Were there any challenges along the way?

Capturing and recording encounter data was our biggest hurdle. We first considered creating an interface between our hospitals and ImagingElements, but this proved to be challenging given the number of hospitals we cover and the limited technical support that we could obtain from each. The ideal solution then presented itself; our billing company, Cvikota, stepped in to act as an intermediary. They offered to collect the necessary information from the many hospitals—indeed they were already collecting much of the information for billing purpose—and then electronically send the information to ImagingElements. This greatly simplified things by only requiring us to create one new interface, an interface between our billing office and ImagingElements. In the end, this has worked extremely well and frankly was easy to do once we found the right team of ImagingElements and our billing office. I highly recommend that other radiology groups in our situation follow a similar course of action to achieve Meaningful Use.

Anything else to add?

Yes. ImagingElements was not just another company selling a certified MU product. They also provided expert guidance on how the complex rules of the Meaningful Use program apply to radiology practices. This additional consultative element was crucial to our success. They have put together a comprehensive set of policies that have been an excellent step-by-step guide for us to follow to ensure that we meet the requirements of this government program.

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Radiologist MU Attestation Update

In this month’s post, we take a look at the latest date regarding radiologist MU attestations.

CMS EHR Incentive Program attestation data, published on, provides a great deal of insight about the reach of the government program. Below, we take a detailed look at radiology-specific data pulled from the latest MU report.

And, as the 2013 meaningful use program participation deadline draws near, we take a look at the latest data available regarding meaningful use and the radiology community.

According to available attestation data at the time of writing, more than $60 million in incentive payments have been paid out to radiologists since the inception of the CMS EHR Incentive Programs in 2011. Millions more are available, but it requires active radiologists to continue participating and those that have not started participating to do so by October 3, 2013 (to receive up to $39,000) or October 3, 2014 (to receive up to $24,000).

The following is based on available attestation data:

Radiologist Participation:
 As of July 2013, 3,213 radiologists (2,975 diagnostic radiologists, 238 interventional radiologists) have attested to Stage 1 Meaningful Use, which equates to approximately 11.9% of eligible radiologists (based on approximately 90% of radiologists meeting program qualification requirements)

CEHRT used for Attestation:
 As of July 2013, more than 75 different certified electronic health record technology (CEHRT) solutions were used for attestation by radiologists. The 10 most widely used CEHRT by radiologists, which account for 72% of radiology attestations, include: Merge Healthcare (426), MedInformatix (422), Epic (387), GE Healthcare (229), Advanced Data Systems (183), Allscripts (156), Partners Healthcare (152), DR Systems (152), UT MD Anderson Cancer Center (101), and Vitera Healthcare Solutions (94).

To view the source data, go to

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How to Implement EHRs (excerpt from

In this month’s post, we take a look at advice from, in partnership with the National Learning Consortium, about How to Implement EHRs., in partnership with the National Learning Consortium, has published a 6-step process about How to Implement EHRs. The following is an excerpt from

Step 1: Assess Your Practice Readiness

The first step in EHR implementation is to conduct an assessment of your current practice and its goals, needs, and financial and technical readiness. With an accurate view of your level of preparedness, your practice can design an implementation plan that meets the specific needs of your practice. 

Step 2: Plan Your Approach

Planning draws on the information gathered during the assessment phase, to outline the practice’s EHR implementation plan. 

Step 3: Select or Upgrade to a Certified EHR

There are a number of steps involved in choosing the right EHR system for your practice. Eligible health care professionals and eligible hospitals must use certified EHR technology in order to achieve meaningful use and qualify for incentive payments. Looking to make your current EHRs meaningful use compliant? Start here. 

Step 4: Conduct Training & Implement an EHR System

EHR implementation involves the installation of the EHR system and associated activities, such as training, mock “go-live,” and pilot testing. 

Step 5: Achieve Meaningful Use

The final phase of EHR implementation includes successfully attesting to demonstrating meaningful use of EHRs, and reassessing what you have learned from training and everyday use of the system. 

Step 6: Continue Quality Improvement

Emphasizes continuous evaluation of your practice’s goals and needs post-EHR-implementation to continue improving workflows that achieve the individual practice’s goals while leveraging the functionality of electronic health records (EHRs).

To read about the full 6-step process, or learn more about a specific step in the process, go to

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Imaging Provider Perspectives

In this month’s post, we take a look at responses to one of the questions posed in the interview chapters of The Radiologist’s Guide to Meaningful Use: A step-by-step approach to the Stage 1 CMS EHR Incentive Programs.

What have you and your organization done to educate yourselves on the fundamentals of meaningful use?

Response: Dr. Keith J. Dreyer, Massachusetts General Hospital

Our CIO introduced me to meaningful use during a presentation in late 2009. I asked if there was a plan to include the radiology department and quickly learned that our team needed to educate ourselves on the ins and outs of the program. We reviewed the literature, examined the timetables, analyzed the standards, implementation specifications, and certification criteria, and assessed the reporting requirements. We also used many of the resources on the CMS EHR Incentive Programs website— fact sheets, summaries, and online video tutorials—to better understand meaningful use and build our strategy.

Response: Dr. Alberto Goldszal, University Radiology Group 

First, let me say that it’s important to start educating yourself now if you haven’t done so already. To educate ourselves on meaningful use we used three primary sources. First, we looked at the basics and general requirements of the program. We attended conferences and lectures and read through various publications. We also relied heavily on word-of-mouth. A second source that we tapped for information was We used this website to better understand the layers under the program as they relate to the medical imaging community—this was invaluable. Lastly, we learned a lot from our RIS vendor, who understood the incentive programs and engaged us early on in the process.

Response: Dr. David Mendelson, Mount Sinai Medical Center

As soon as the ARRA of 2009 and HITECH Act were announced, our organization immediately established a cross-functional committee at the clinical level and began analyzing all of the relevant federal documents that were available at the time. We reviewed those documents line-by-line and distilled that information into a summary document that outlined things we had to do and questions we needed answered—it essentially became a working document to guide us.

As soon as the timelines were announced, we began planning on both the inpatient and ambulatory sides. We conducted a financial analysis that included billing data for Medicare and Medicaid and identified whom on the clinical staff, and later radiology staff, would be eligible for incentive opportunities.

Specific to radiology, we are staying apprised of the program by using resources like and medical society websites, speaking with colleagues about their strategies, and closely monitoring changes and clarifications to the regulations.

We really are focused on understanding the financial implications, who is eligible, who is not eligible, what our vendors are doing, and how they will support our strategy. We’re also evaluating different approaches and looking at our RIS, our hospital EHR, as well as other certificated technology that we might be able to leverage to achieve meaningful use.

Response: Steven Fischer, Center for Diagnostic Imaging

The most valuable information came directly from CMS—including details about incentive payouts, eligibility determination, and general guidance and clarification. We also reviewed the regulations, certification processes and test scripts, and looked at trade magazines as well as a variety of online resources. We basically scoured all of the available content to find whatever information we could. 

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Office of the Inspector General MU Report

In this month’s post, we take a look at the HHS Office of the Inspector General’s (OIG) early (November 2012) assessment of the CMS oversight of the Medicare EHR Incentive Program. The following is an excerpt from the executive summary of the report, Early Assessment Find That CMS Faces Obstacles In Overseeing The Medicare EHR Incentive Program (OEI-05-11-00250).

Why did the OIG do this study?

This study is an early assessment of CMS’s oversight of the Medicare electronic health record (EHR) incentive program, for which CMS estimates it will pay $6.6 billion in incentive payments between 2011 and 2016. Because professionals and hospitals self- report data to demonstrate that they meet program requirements, CMS’s efforts to verify these data will help ensure the integrity of Medicare EHR incentive payments.

How did the OIG do this study?

This study reviewed CMS’s oversight of professionals’ and hospitals’ self-reported meaningful use of certified EHR technology in 2011, the first year of the program. To address our objective, OIG analyzed self-reported information to ensure it met program requirements. OIG also reviewed CMS’s audit planning documents, regulations, and guidance for the program, and conducted structured interviews with CMS staff regarding CMS’s oversight.

What did the OIG find?

CMS faces obstacles to overseeing the Medicare EHR incentive program that leave the program vulnerable to paying incentives to professionals and hospitals that do not fully meet the meaningful use requirements. Currently, CMS has not implemented strong prepayment safeguards, and its ability to safeguard incentive payments postpayment is also limited. The Office of the National Coordinator for Health Information Technology (ONC) requirements for EHR reports may contribute to CMS’s oversight obstacles.

To read the entire report, and learn about the OIG’s recommendation, go to

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