CMS and ONC issued three Notices of Proposed Rule Making (NPRMs) in quick succession during March and April that have a major effect on what to expect for Stage 3 of Meaningful Use (MU3). These NPRMs affect both the content of MU3 and also how it and earlier stages are likely to roll out. If you want, you can read the relevant 242 Federal Register pages here, here, and here. Take your time. I’ll wait.
People involved in imaging have had a few months now to fully digest these proposed rules. But there seems to be a lot of confusion out there. Many remain a bit puzzled by what it all means in practical terms.
Also, if you read my three earlier posts covering Stage 2 of Meaningful Use (MU2) in depth with a focus on the Image Results objective, you might wonder how much of that advice is still applicable. Well, the answer is: pretty much none of it is relevant anymore.
If you have not already attested to Image Results objective you should probably not be investing any further effort in doing so. If you are interested in the details, keep reading.
A Change in Direction
Some leaders in the imaging industry assumed that we would see increased requirements for medical imaging in Meaningful Use Stage 3. There was talk of Image Results moving from a menu item to a core item and new mandates for including DICOM images in the View/Download/Transmit objective. None of this happened.
The government is apparently sensitive to earlier criticisms from providers about: [a] putting too much in Stage 1 and 2 too fast and [b] not doing enough to ensure interoperability between systems. So this time around there was a double mantra of streamlining and focus. Which means many things not in focus got shunted to the curbside, including the aforementioned Image Results.
You will still find Image Results listed in the roster of criteria But it is now one of the low effort orphans of Table 7 on page 16898 (CRITERIA NOT ASSOCIATED WITH THE EHR INCENTIVE PROGRAMS STAGE 3).
It appears that the US government still considers being able to view radiology and cardiology images directly from a patient’s records in the EHR a good idea. But since it seems so easily accomplished (typically <20 hours of effort needed), Image Results will get you no credit in when you go to attest for Stage 3.
Where Everyone Stood When the Music Stopped
McKesson conducted a broad survey of hospitals and imaging centers throughout the United States in June 2015. This survey shows that of the respondents who knew whether or not they had attested to Image Results, 43% had already attested to the Image Results objective.
Of the remainder that had not yet attested to this objective, more than half were technically capable of doing so (i.e, their users already have ready access to images from a patient’s records in the EMR).
Only 22% of the respondents currently lacked this technical capability to attest to Image Results.
An Uncertain Objective
But this same survey also revealed a fair amount of confusion related to forward planning around the Image Results objective that varies with how far the organization has reached attesting to MU stages. The 3 pie charts below illustrate this situation:
In each chart the red pie slice shows the proportion of respondents who are still planning to attest to Image Results. In the case of folks who have not reached any stage, this is 25%; those who have attested to stage 1, 63%; and those who have attested to stage 2%.
The problem is that they probably will not get a chance to do this.
Currently the Attestation System is not available until further notice for Eligible Hospitals and Eligible Professionals to attest for the Medicare Electronic Health Record Incentive Program for Program Year 2015, so it is not accepting new attestation data for MU2 (the stage that introduced Image Results). By the time it opens again the last NPRM I linked to at the top of this article will be enacted and, unless modified, will remove Image Results from MU2 as well, as part of a harmonization with MU3. So the Image Results window is effectively closed.
That is likely why you see a lot of green pie slices in the charts labeled “Skipping”. These organizations have anticipated that the NPRMs are unlikely to be changed to put Image Results back in scope of either MU2 or MU3 and therefore they are not wasting any effort pursuing this objective.
The large, blue “Uncertain” pie slices also show that many organizations are still working through these questions.
Wasted Effort and a Short Menu
It is not the end of the world if an organization has gone to the trouble of image-enabling their EMR. After all, CMS thinks it does not generally take a lot of effort and physicians are all in favor of having this capability.
The biggest concern here is that a number of organizations in the middle chart are actively doing their data gathering for their MU2 submission – if the 62% of these who were planning on attesting to Image Results were counting on that to reach the minimum number of MU2 menu objectives during attestation later on, these organizations could find themselves short an objective.
Is There Anything Else About Imaging in Stage 3?
One of the few things that might bring the MU3 team to the door of the radiology department is to talk about clinical decision support (CDS) for ordering appropriate studies. This falls under the general Meaningful Use CDS objective. But, realistically, this kind of CDS is all about integrating effectively with the Computerized Physician Order Entry (CPOE) in the EMR.
Of course, approximately 35% of institutions in our survey have already rolled out this form of CDS and another 34% are in the planning stages. Given the separate and looming January 1, 2017 Congressional mandate for use of CDS in ordering Medicare studies, this is an easy choice for organizations to make towards MU progress – it’s a double win.
Measure 5 (Clinical Data Registry Reporting) of the proposed Public Health Reporting objective of MU3 could have some relevance to Radiology and Cardiology, given the ACR and ACC registries to which these departments feed data. But it is likely that many organizations will already be attesting with a number of the more common measures. So it is unclear whether the ACR or ACC registries will need to be pulled into the mix by an organization for MU3.