Practice Obtains MU Incentives with Some Help from its Longtime Technology Partner

In this month’s post, we take a look at a MU success story from Hartsdale Imaging in Hartsdale, NY.

Hartsdale Imaging (HI) in Hartsdale, NY has five fellowship-trained, board-certified radiologists combining both interventional and a full array of conventional multi-modality procedures.

Maintaining its tradition of innovation, forward-thinking HI became part of the first wave of imaging centers to tackle the challenges of MU for radiology in order to obtain Medicare incentives. However, a specific MU challenge was that the practice handled both patient encounters and standard radiology visits.

Fortunately, HI did not have to look any further than its own “backyard” where ADS technology had been helping the practice hum with efficiency for more than twenty years. ADS systems used include MedicsRIS and MedicsPremier for radiology PM.

Joseph Casoria, HI’s Practice Administrator noted that ADS worked closely with HI’s staff in mapping out a strategy that would most efficiently enable MU compliance with a minimum of interruption to existing workflows.

ADS reviewed how the MedicsDocAssistant EHR for Radiology would be able to support HI’s MU strategy and discussed how other ADS radiology clients successfully attested for MU. HI’s radiologists have since attested twice for Stage 1, receiving both sets of incentives and they are now looking forward to attesting to Stage 2.

“The built-in Medics MU Dashboard was an invaluable tool in reporting on the radiologists’ individual MU progress,” Casoria noted.

Besides their own incentives, HI uses MedicsConnect from ADS, a built-in capability in MedicsRIS enabling HI to securely transmit their radiology reports (via SFTP) directly to their referring physicians’ EHRs. This helps HI’s referring physicians satisfy one of their major Stage 2 requirements in the process.

Mr. Casoria said, “MedicsConnect has brought the delivery of HI’s radiology reports to a new level. Our referring physicians love how our reports are received cleanly, and in EHR-enabled format. Without question, MedicsConnect helps keep our referrers referring.”

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Proposed Last Minute MU Flexibility is a Gamble

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

A great update posted on Radiology and HIT Blog discusses the Centers for Medicare and Medicaid Services (CMS) and Office of the National Coordinator for HIT (ONC) May 23, 2014 proposed rule to allow continued use of 2011 Edition certified EHR technology to comply with the Medicare EHR Incentive Program in calendar year (CY) 2014.

Background

The ONC’s 2014 Edition EHR certification criteria regulations for HIT products were published in September 2012. A few months later, vendors were able to submit ready products to the testing labs and certification bodies for 2014 Edition certification. Eligible professionals could opt to use 2014 Edition certified products to comply with Meaningful Use (MU) beginning in CY 2013, and the new certification status became mandatory in CY 2014. Most HIT products were not ready to be 2014 Edition certified in time for prior MU participants to take advantage of that flexibility in CY 2013 due to their yearlong reporting period. However, new MU participants only had a 90-day reporting period in CY 2013, and thus were encouraged to implement 2014 Edition certified products instead of implementing 2011 Edition products (to avoid having to upgrade again so soon).

As CY 2013 wore on, it became clear that many vendors who had commercially successful 2011 Edition certified products were not getting new versions of those products updated and submitted for testing/certification in a timely fashion. By the time most vendors were ready, there was an alleged backlog of products in the testing and certification pipeline, which apparently caused more delays.

Read more about the background, concern, and conclusion on Radiology and HIT Blog.

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ONC Updates the 2014 Edition Test Method

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

The Office of the National Coordinator for HIT (ONC) released an update to the 2014 Edition Test Method that supports the testing and certification of health IT products used in the Medicare/Medicaid EHR Incentive Program. Specifically, the test procedure for the key “automated numerator recording/automated measure calculation” certification criterion was modified. Also updated were the test data associated with that procedure, and the test data associated with the procedure for the “data portability” criterion.

While primarily meant for testing labs and certification bodies, the 2014 Test Method is also an important resource for industry because it essentially shows how functionality will be tested against ONC’s various certification criteria. This allows for more efficacious planning prior to product submission.

To view the original posting, please visit the Radiology and Health IT Blog.

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Meaningful Use Penalty Avoidance Deadline July 1, 2014

In this month’s post, we take a look at details related to meaningful use penalty avoidance.

A helpful reminder posted on Radiology and HIT Blog discusses the approaching penalty avoidance deadline.

The application deadline for obtaining one of the significant hardship exception options from calendar year (CY) 2015 EHR Incentive Program penalties is July 1, 2014. Beyond the application-based hardship exception options, there are automatically-granted significant hardship exception options for newly practicing physicians and physicians whose primary specialty codes in PECOS are “diagnostic radiology” (30), “nuclear medicine” (36), “interventional radiology” (94), anesthesiology (05), or pathology (22) as determined approximately six months prior to the penalty year (so, also July 1, 2014).

Importantly, most American College of Radiology members will not need to take any further action to avoid the CY 2015 penalties other than to double-check their own PECOS data to make sure their primary specialty code is 30, 36, or 94. Radiation oncologists and other radiologists with different primary specialty codes will need to either demonstrate Meaningful Use (MU) by the appropriate deadline in 2014 or manually apply for one of the other significant hardship exceptions before July 1.

Links to resources:

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

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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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2014 CEHRT Hardship Exception Guidance for EPs

In this month’s post, we take a look at the 2014 CEHRT Hardship Exception Guidance for Eligible Professionals (EPs). 

If you are an eligible professional, and you are unable to implement the 2014 Edition of Certified Electronic Health Record (EHR) Technology in time to successfully demonstrate meaningful use for the 2014 reporting year, you may be eligible for a hardship exception from the applicable Medicare payment adjustment.

When do payment adjustments take effect for the 2014 reporting year?

The Medicare EHR Incentive Program payment adjustment is applied in 2016 for the 2014 reporting year for providers who demonstrated meaningful use in a previous year. New participants in the 2014 reporting year can also apply for an exception to the 2015 payment adjustment. CMS is currently accepting hardship exception applications for the 2015 payment adjustment only.

New Participants in 2014

If you are new to the program and intended to demonstrate meaningful use for the first time in 2014, but you are not able to implement 2014 certified EHR technology for the 2014 reporting year, you may apply for a hardship exception for the 2015 payment adjustment.

  • Use the eligible professional hardship exception form for 2015
  • Indicate the reason you are applying for a hardship (select “2014 Vendor Issues”)
  • Submit your application by July 1, 2014

Returning Meaningful Users in 2014

If you successfully demonstrated meaningful use for the 2013 reporting year, you will not be subject to the 2015 payment adjustment. If you are not able to implement 2014 certified EHR technology for a 2014 reporting period, you may apply for a hardship exception for the 2016 payment adjustment.

  • Use the eligible professional hardship exception form for 2016 which will be available after July 1, 2014
  • Indicate the reason you are applying for a hardship (select “2014 Vendor Issues”)
  • Submit your application by July 1, 2015

For more information, please review the 2014 CEHRT Hardship Exception Guidance for Eligible Professionals documentation posted on the CMS website: http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/CEHRT2014_HEGuidance_EPs.pdf

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ONC 2015 Edition Certification Criteria Proposed Rule

In this month’s post, we take a look at the ONC 2015 Edition Proposed Rule.

The 2015 Edition Proposed Rule introduces the beginning of the Office of National Coordinator for Health Information Technology’s (ONC’s) more frequent approach to health information technology certification regulations. Under this approach, ONC intends to update certification criteria editions every 12 to 18 months in order to provide smaller, more incremental regulatory changes and policy proposals. This approach gives stakeholders greater and earlier visibility into our regulatory direction before compliance is required, provides more time for public input on policy proposals under consideration for future rulemakings, and enables our certification processes to more quickly adopt newer industry standards that can enhance interoperability.

The 2015 Edition EHR certification criteria proposed in this rule would be voluntary. No EHR technology developer who has certified its EHR technology to the 2014 Edition would need to recertify to the 2015 Edition in order for its customers to participate in the EHR Incentive Program. Furthermore, eligible professionals, eligible hospitals, and critical access hospitals that participate in the EHR Incentive Programs would not need to “upgrade” to EHR technology certified to 2015 Edition in order to have EHR technology that meets the Certified EHR Technology (CEHRT) definition. Instead, the 2015 Edition EHR certification criteria would accomplish three policy objectives:

  • Enable a more efficient and effective response to stakeholder feedback
  • Incorporate ”bug fixes” to improve on 2014 Edition EHR certification criteria in ways designed to make our rules clearer and easier to implement
  • Reference newer standards and implementation specifications that reflect our commitment to promoting innovation and enhancing interoperability

The proposed rule was published in the Federal Register on February 26, 2014. ONC will accept comments on the proposed rule through April 28, 2014 via regulations.gov. A voluntary public comment template offers a simple and organized way to submit comments on the proposed certification criteria and associated standards and implementation specifications, and respond to specific questions posed in the preamble of the proposed rule. The final rule is expected to be issued in summer 2014.

Proposed Rule (Federal Register): http://www.gpo.gov/fdsys/search/pagedetails.action?granuleId=2014-03959&packageId=FR-2014-02-26&acCode=FR

Public Comment Template: http://healthit.gov/sites/default/files/2015editionnprm_public_comment_template_final.docx

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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: http://www.healthit.gov/policy-researchers-implementers/about-certification).

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//www.healthmu.org/radiology/beyondstage1.php.

Ready to learn more, buy a book today! 

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MU Takes the Stage at RSNA 2013

In this month’s post, we take a look at news and industry updates from RSNA 2013.

Meaningful use is one of the most discussed topics across all health care specialties—and radiology is no exception. The challenges that the imaging community faces, and experiences of those that have already tackled this government program, were shared at the recent Radiological Society of North America annual conference.

RSNA 2013 offered a number of educational tracks and sessions dedicated to the subject. From information packed sessions for radiology IT providers, to discussions with leaders in the field, there was something for everyone impacted by the CMS EHR Incentive Programs. What’s more, this year’s conference featured dozens of new solutions designed for, and used for attestation by, radiology professionals.

Furthermore, a number of feature articles have been published over the past 2 weeks that focus on the topic of meaningful use and provide an excellent recap of the sessions and discussions that took place at the conference.

MU News from RSNA 2013

  • HealthDataManagement.com: Radiologists Share Diverse Meaningful Use Experiences –Read more…
  • DiagnosticImaging.com: Should Hospital-based Radiologists Pursue Meaningful Use? – Read more…
  • DiagnosticImaging.com: Some Radiologists Embrace Meaningful Use, Others Wait –Read more…
  • ImagingBiz.com: Take a Long View of MU –Read more…
  • TechTarget.com: New RIS workflows making EHRs look low-tech – Read more…

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).

Meaningful Use at RSNA 2013

In this month’s post, we take a look at meaningful use sessions and lectures at RSNA 2013.

Nearly 55,000 radiology professionals from around the world will converge on Chicago to witness the latest discoveries, techniques and innovations for diagnostic imaging – 2,000 education exhibits, 300 peer-reviewed refresher courses, and 2,500 scientific presentations. Below is a list of lectures and sessions about meaningful use that will support your participation in the CMR EHR Incentive Programs.

Monday 12/02/13 (4:30-6:00PM/ICII24): Meaningful Use for Radiology IT Vendors: What your Customers will Demand, and your Competition will Provide

Presenter(s): David E Avrin MD, PhD; Keith J Dreyer DO, PhD 

Even with Phase II rules of Meaningful Use, the fit with Radiology remains a challenge. The focus of the federal agencies remains on the primary care practices of internal medicine, family practice, and pediatrics. However, with recent refinement of the US Federal Health IT rulings for Meaningful Use (MU), it is hoped that some US radiologists will be eligible for substantial CMS incentives. Collectively, these incentives could total over $1 billion for radiologists alone. Up to $44,000 is available per qualifying Eligible Provider. As important, incentives may turn to penalties within a few years. MU was initially targeted towards primary care specialties, but under certain circumstances could apply to diagnostic radiology.  Eligibility for MU will depend upon the individual radiologist’s practice scenario. Some technology will come from existing infrastructure (including RIS, PACS, Reporting Systems) and others will come from new purchases (including Decision Support, Data Mining, Image Sharing and Patient Portals).

In this lecture, the presenters will describe ways to analyze your existing portfolio of products to determine which MU measures they should be eligible for, and to define a pathway toward MU certification of these modules.

Further, we will discuss the ability to determine what additional functionality might be added to your existing products to expand your MU certification offerings. Finally, we will explore ways for your company to provide all remaining MU measures, beyond your existing product portfolio, so that your existing and future customers can achieve Meaningful Use. We will also review results of an RSNA sponsored survey to propose a set of criteria that more appropriately define true MU for radiology to affect future federal rule setting when they move beyond primary care specialties.

Tuesday 12/03/13 (12:30-2:00PM/ICII32): Meaningful Use: Experience from Private Radiology Practices

Presenter(s): J. Raymond Geis MD; James Whitfill MD; Alberto F Goldszal PhD, MBA; Alan D Kaye MD

Learning objectives for this course include: 1) Learn how various radiology practices have approached Meaningful Use to date. 2) Understand the challenges of achieving Meaningful Use compliance with existing vendor products available today. 3) Explore ways to participate with either your hospital or multi-specialty practice to achieve Meaningful Use.

Wednesday 12/04/13 (12:30-2:00PM/ICII42): Meaningful Use: Experience from Radiology Practices in Hospitals and Health Systems

Presenter(s): Ramin Khorasani MD; Curtis P Langlotz MD, PhD 

Learning objectives for this course include: 1) Understand the meaningful use program. 2) Learn how hospitals and health systems have achieved meaningful use for their radiologists. 3) Decide how your practice should respond to the program. 

Thursday 12/05/13 (8:30-10:00AM/RC626): Latest Developments in Meaningful Use: Ask the Experts

Presenter(s): Curtis P Langlotz MD, PhD; Keith J Dreyer DO, PhD; Michael Peters

Learning objectives for this course include: 1) Understand the meaningful use program. 2) Learn how hospitals and health systems have achieved meaningful use for their radiologists. 3) Gain insight into recent and upcoming regulatory changes, and 4) Decide how your practice should respond to the program. 

For more information, search the full RSNA 2013 Meeting Program.

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).