Part 3 of 3: Some Practical Advice on Image Results and Meaningful Use Stage 2

2014-06-24
 

Discover Meaningful Use Advice for Medical Practices from the Medical Imaging Talk Blog

[Note: Read part 1 of this series here and part 2 of the series here]

What is Image Results Anyway?

“Image Results” is the name of a Meaningful Use 2 menu objective. So you could conceivably just opt out of doing it if you already have six of the other menu objectives well covered. But since most hospitals will find it to be a quick win and it is so valuable to quality patient care, it would be a shame not to address it. Also, it is probably going to be core in MU3, so why put it off?

The Image Results objective is based on the concept that it might be easier for the doctors and nurses to understand what the radiologist or cardiologist is talking about in their reports if they could see the images on which the reports are based. Sometimes a picture is worth a thousand words. And a picture with a big red arrow on it is often worth even more.

Officially, the Image Results objective is designated as 170.314(a)(12) and is defined as follows:

Imaging results consisting of the image itself and any explanation or other accompanying information are accessible through CEHRT.

You may already be doing this. It is easy to check. Just go into your EHR, find a patient who has had a radiology exam at your hospital, and view his or her report. If there is a link or button beside the report that lets you view the images associated with the study and the link or button actually shows you images then, congratulations, you are most of the way there—skip to the next section.

If the above steps did not let you look at images, you need to do some work. But this is probably a project that the imaging departments at your hospital have wanted to do for years only it kept getting deferred in priority—and now you have the golden ticket: Meaningful Use. If you are using a McKesson system to manage your images you can get this rolling by calling up your McKesson representative and ordering EHR image integration.

Otherwise, you should call up your imaging vendor and see if they can help you in a useful timeframe. Image enabling an EHR is not a new thing. Most imaging vendors have long had this option available.

Attesting: Numerator and Denominator

The government doesn’t just take your word that your hospital is golden with respect to your target Meaningful Use objectives. You actually need to show some evidence. Also, you fortunately do not have to achieve a 100 percent success rate in making images available in this manner. In fact, the target threshold percentage in MU2 is an easily achievable 10 percent. Expect this threshold to be higher in MU3.

Like any other ratio, this one involves a numerator on top divided by a denominator on the bottom. These are helpfully defined by CMS:

DENOMINATOR: Number of tests whose result is one or more images ordered by the EP during the EHR reporting period.

NUMERATOR: The number of results in the denominator that are accessible through CEHRT.

The ONC has further weighed in with some additional guidance. First, “images” in the denominator means both radiology and cardiology, but not other specialties (at least for stage 2). Many organizations mistakenly assumed “images” meant radiology only. Secondly, ordered tests that create images, but which for some reason the institution does not store these electronically (e.g., they are still kept only on film for some reason) are included in the denominator. You will need to account for these “zero-image studies” by deducting from your potential numerator or address the underlying cause so your users do have access to the images digitally (e.g., purchase a film scanner).

Additionally, there is an exclusion defined by CMS, which could be used to weed out studies from the numerator and (more importantly) the denominator in order to help you get to a higher percentage relative to the threshold:

EXCLUSION: Any EP who orders less than 100 tests whose result is an image during the EHR reporting period; or any EP who has no access to electronic imaging results at the start of the EHR reporting period.

However, I will be surprised if an organization, in practice, needs to utilize the exclusion. Typically you would expect that every radiology report that has digital images associated with it can be called up.

What about Cardiology?

Optimally, your cardiology reference image viewer is the same as your radiology reference viewer, and thus your numerator contains them both. However, even if this is not the case, all is not lost. Remember your target for Meaningful Use 2 is only 10 percent of your denominator. A typical institution is going to have a radiology study volume that is substantially higher than the cardiology study volume, and many times 10 percent of the combined radiology and cardiology volume (i.e., the denominator). So you can make cardiology access a Meaningful Use 3 time line goal and just focus on radiology for now.

Solving the “Too Many Viewers” Problem

But what if you have multiple campuses each running their own PACS, each with its own viewer? If this is the case, you should concentrate on connecting the EHR to the single viewer that gives access to the most studies. As long as that pool of studies accessible to that viewer is more than 10 percent of your combined radiology and cardiology volume, then you can still meet the Meaningful Use 2 threshold. Or you could purchase and rapidly deploy a solution to unify your image pool behind a single viewer, since ultimately you are going to want to do that anyway.

Modular Certification

If your PACS, VNA, or universal viewer vendor has been on the ball then they will have modular certification already in place that covers the Image Results certification criteria. You can check this by searching on the government’s CHPL (pronounced “chapel”) web accessible database. If your vendor is on the list for the “Image Results” objective you will just need to reference their official certificate as part of your submission to the government along with your supporting threshold data. You can obtain the modular certificates for McKesson enterprise medical imaging products here.

However, if your viewing solution does not have modular certification then you are facing a great deal of additional work and expense because you would need to self-certify. Basically, your institution is going to have to do what your vendor would have normally done to prove their product has the necessary functionality to meet the objectives. This involves contracting a qualified agency (ATL in MU speak) to run your solution through ONC’s test scripts. Unless you are going to be doing a lot of self-certification to meet other objectives and thus already have an ATL engaged this route probably doesn’t make a lot of business sense. You also run the risk of finding out late in the game that your viewing solution does not pass the script — and that you are now short of your needed objectives. In this case, you might be better served to either pick another menu objective instead of Image Results or switch to a viewer solution that already has modular certification.

Learn more about Meaningful Use stage 2 objectives and certification by downloading the full blog series Some Practical Advice on Image Results and Meaningful Use Stage 2.

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