Meaningful Use Guidelines: Radiologists

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Call: (347) 396-4888 | Visit: www.nycreach.org | E-mail: [email protected]

For NYC REACH members only — DO NOT DISTRIBUTE.

Meaningful Use Guidelines:

Radiologists

NYC REACH Services Overview

Radiologists may qualify for up to $63,750 under the Medicaid EHR

Incentive Program for the adoption, implementation, and upgrade (AIU) of

a certified EHR and Meaningful Use achievement.

The Medicaid Specialist Program at NYC REACH aims to assist eligible

healthcare specialists including Radiologists with achieving Meaningful

Use (MU) requirements via New York State’s Medicaid EHR Incentive

Program.

Radiologists are eligible if they are:



Meeting a 30% Medicaid patient volume



Enrolled as Medicaid Fee for Service



Billable and payable by Medicaid



In good standing with New York State

Year 1: Adopting, Implementing, or Upgrading (AIU)

Incentive Payment: $21,250

For the first year, eligible providers must complete AIU of a certified EHR.

This is accomplished by either implementing an EHR or upgrading to a

certified EHR.

Year 2: 90-day Meaningful Use Reporting Period

Incentive Payment: $8,500

For the second year, eligible providers must meet a set of 15 core and 5 of

10 menu MU measures over a consecutive 90-day period, including the

submission of Clinical Quality Measures, to demonstrate meaningful use

of the EHR to improve and coordinate patient care.

Year 3

*

to Year 6: Continuing Meaningful Use

Incentive Payment per year: $8,500

After the second year participation, successful attestation requires an entire

calendar years’ tracking of MU, including the submission of Clinical Quality

Measures. This leads to a maximum payment total of

$63,750 over all six

participation years.

Meaningful Use

Meaningful Use (MU) criteria allows

providers to demonstrate that they

are using certified EHR technology in

ways that can be measured

significantly in quality and in

quantity.

Many Radiologists assume that they

cannot meet Meaningful Use since

many of the MU measures do not

reflect the clinical work done in a

Radiology practice. This is not true.

If a certain MU measure does not

apply to or is not done in the normal

scope of a specialty or Radiology

practice, then the Radiologist can

claim an exclusion, if applicable, for

that measure. It is the provider’s

responsibility to determine whether

he or she may claim an exclusion for

speciﬁc measures that oﬀer

exclusions.

The goal of the Medicaid EHR

Incentive Program is to have eligible

professionals (EPs) file (or “attest”)

for 6 years in total. However, if

problems arise such as system

tracking of MU measures, providers

can skip a year’s filing.

The first year is always AIU (adopting,

implementing or upgrading to a

certified EHR), followed by a second

year of meeting the MU measures for

90 days. The third and subsequent

years require a full years’ tracking of

the measures.

*If the provider is attesting for Medicaid Year 3 in 2014, then he or she can complete Meaningful Use for a 90-day period and not the original rule of a full year. This is only for 2014.

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For NYC REACH members only — DO NOT DISTRIBUTE. 2

Meaningful Use Guidelines:

Radiologists

Requirements for Meaningful Use Stage 1:

EPs must complete these requirements for a 90-day reporting

period during participation year 2 and for a 1 year reporting

period in the calendar year for participation years 3 to 6.

*

*If the provider is attesting for Medicaid Year 3 in 2014, then he or she can

complete Meaningful Use for a 90-day period and not the original rule of a full year. This is only for 2014.

MU Stage 1: Core Set Requirements

Eligible Professionals (EPs) must attest to (or take an exclusion,

where applicable, for) all 15 MU Stage 1 Core Set objectives.

MU Stage 1 Core Set Requirements:



10 core threshold objectives (measures reported for a minimum %

of patients)



5 core activity objectives (measures to illustrate capabilities,

functionality, and security)

MU Stage 1: Menu Set Requirements

In addition to meeting all MU Stage 1 Core Requirements, EPs must

also attest to (or take an exclusion, where applicable, for) 5 out of 10

MU Stage 1 Menu Set Objectives.

MU Stage 1 Menu Set Requirements:



5 out of 10 Menu Set Measures, including:

-Public Health Reporting (PHR) Requirement:

Must pick 1 of 2 public health reporting objectives

Please see the accompanying charts on pages 3-7 for specific details

about each Core and Menu Set Objective, including applicable

exclusion policies. For a comprehensive list of all MU measures

(including attestation requirements for each measure), visit:

https://

www.cms.gov/Regulations-and-Guidance/Legislation/

EHRIncentivePrograms/Downloads/EP-MU-TOC.pdf

Exclusion Example for

Meaningful Use (MU)

Measures

The MU measures relating to electronic

prescriptions (e-prescribing) demonstrate an

instance whereby a Radiologist could qualify to claim an exclusion (e.g., the MU

objectives may not be applicable to a particular specialist’s scope of practice.) For example, one MU measure requires a provider to enter prescription orders into his or her EHR system (e.g., Computerized Prescription Order Entry, or CPOE). Another MU measure requires the provider to generate and submit/transmit these prescriptions electronically.

If a Radiologist does little or no prescribing, however, then he or she could claim an exclusion for this measure. The exclusion

does not prevent a provider from meeting MU.

The exclusion for these two measures states:

“An Eligible Professional (EP) who writes fewer than 100 prescriptions during the EHR reporting period would be excluded from this requirement. Exclusion from this requirement does not prevent an EP from achieving meaningful use.”

Be sure to maintain all documentation justifying any exclusions that one decides to claim for certain MU measures.

In this way, Radiologists can still

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Meaningful Use Guidelines:

Radiologists

Meaningful Use: CORE Set Measures

(ALL 15 Required)

Suggested Methods for Radiologists

1: CPOE for medication orders: More than 30% of unique

patients with at least one medication in their medication list seen by the EP have at least one medication order entered using CPOE.

Optional Alternate: More than 30% of medication orders

created by the EP during the EHR reporting period are recorded using CPOE.

Exclusion: Any EP who writes fewer than 100 prescriptions

during the EHR reporting period.

-Order all medications through the EHR.

-Radiologists may be exempt if they order fewer than 100 prescriptions during the reporting period. EPs must attest to the number of prescriptions written during the reporting period to qualify for exclusion.

2: Drug-drug and drug-allergy checks: The EP has enabled

this functionality (e.g. it is turned on in your EHR system) for the entire reporting period.

No exclusion.

-Work with your EHR vendor, system administrator and/or site manager to make sure this functionality is enabled.

3: Up-to-date problem list: More than 80% of all unique

patients seen by the EP have at least one entry (or an indication that no problems are known for the patient) recorded as structured data.

No exclusion.

-Review and update the problem list prior to treatment. -If the patient has no active problems, indicate/document this data in the EHR.

4: E-Prescribing: More than 40% of all permissible

prescriptions written by the EP are transmitted electronically using certified EHR technology.

Exclusion: Any EP who writes fewer than 100 prescriptions during the EHR reporting period.

-Order/transmit all prescriptions electronically through EHR (faxing does not count) in place of a written prescription, whether the pharmacy is on-site or off-site -Radiologists may be exempt if they order fewer than 100 prescriptions during the reporting period. EPs must attest to the number of prescriptions written during the reporting period to qualify for exclusion.

5: Active medication list: More than 80% of all unique patients

seen by the EP have at least one entry (or an indication that the patient is not currently prescribed any medications) recorded as structured data.

No exclusion.

-Review and update the medication list prior to treatment. -If patient was prescribed medications from an outside provider or had any prescription filled outside the facility, enter current medications into the active medication list in the EHR.

-If patient is not on any medications, indicate/document this data in the EHR.

6: Active medication allergy list: More than 80% of all unique

patients seen by the EP have at least one entry (or an indication that the patient has no known medication allergies) recorded as structured data.

No exclusion.

-Review and update the medication allergy list prior to treatment.

-If patient has no medication allergies, indicate/document this data in the EHR.

7: Demographics: More than 50% of all unique patients seen

by the EP have preferred language, gender, race, ethnicity, and date of birth recorded as structured data.

No exclusion.

- Ensure that your facility has a process to capture this data for all patients. This information is typically obtained through patient registration.

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Meaningful Use Guidelines:

Radiologists

Meaningful Use: CORE Set Measures

(ALL 15 Required)

Suggested Methods for Radiologists

8: Vital signs: For more than 50% of all unique patients age 2 and over seen by the EP, height, weight and blood pressure are recorded as structured data. New Measure (Optional 2013; Required 2014 and beyond): For more than 50% of all unique patients seen by the EP during the EHR reporting period have blood pressure (for patients age 3 and over only) and height and weight (for all ages) recorded as structured data.

Exclusion: Any EP who either sees no patients 2 years or older, or who

believes that all three vital signs of height, weight, and blood pressure of their patients have no relevance to their scope of practice.

New Exclusion (Optional 2013; Replaces exclusion above in 2014):

Any EP who :

1. Sees no patients 3 years or older is excluded from recording blood pressure; 2. Believes that all three vital signs of height, weight, and blood pressure have no relevance to their scope of practice is excluded from recording them; 3. Believes that height and weight are relevant to their scope of practice, but blood pressure is not, is excluded from recording blood pressure; or

4. Believes that blood pressure is relevant to their scope of practice, but height and weight are not, is excluded from recording height and weight.

-Review the patient’s EHR data at each visit to verify that height, weight, and blood pressure have been recorded. -If height, weight, and blood pressure are not current, take these measurements and record in the EHR as structured data

9: Smoking status: More than 50% of all unique patients 13 years old or older seen by the EP have smoking status recorded as structured data.

Exclusion: Any EP who sees no patients 13 years old or older during the reporting period.

-Review the patient’s Health Summary or the EHR at each visit to verify that smoking status has been

recorded.

-If not, record smoking status in the EHR as structured data

10: Report Clinical Quality Measures to CMS:

-Each EP must report on the 3 CQMs in the core set (hypertension, tobacco use assessment/intervention, and adult weight screening).

-Each EP must substitute CQMs from the alternate core set (weight

assessment/counseling for children, influenza immunization for adults, and childhood immunizations) for any measure in the core set with a zero denominator.

-Each EP must also select and report on three additional clinical quality measures that are relevant to the EP’s practice.

No exclusion.

Based on the measure choices available through the specific EHR model/vendor being used, Radiologists might consider selecting the following measures from the 38 additional CQM choices:

- Oncology Breast Cancer: Hormonal Therapy for Stage IC-IIIC Estrogen Receptor/Progesterone Receptor (ER/PR) Positive Breast Cancer (NQF# 0387)

- Oncology: Medical & Radiation – Pain Intensity Quantified (NQF# 0384) (2014+ only)

- Oncology Colon Cancer: Chemotherapy for Stage III Colon Cancer Patients (NQF# 0385)

- Diabetes: Blood Pressure Management (NQF #0061) - Pneumonia Vaccination Status for Older Adults (NQF #0043) 11: Clinical decision support: Implement one clinical decision support rule

relevant to specialty or high clinical priority along with the ability to track compliance of that rule. No exclusion.

-Work with your EHR vendor, system administrator and/or site manager to make sure reminders are configured correctly.

-Radiology-specific clinical decision support rules are not required.

12: Electronic copy of health information: More than 50% of all patients seen by the EP who request an electronic copy of their health information are provided it within 3 business days.

Exclusion: Any EP who receives no requests for electronic copies of health information.

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Meaningful Use Guidelines:

Radiologists

A Note on

Certified EHRs

Radiologists must use certified EHRs in

order to participate in the NY Medicaid

EHR Incentive Program.

The ONC (Office of the National

Coordinator for Health Information

Technology) has confirmed, however,

that EPs may use an uncertified product

to feed information into a certified EHR

product. As long as required MU

information is being captured by the

certified EHR product it will count

towards achieving meaningful use.

For additional information on ONC

Certified EHR Technology visit:



http://www.cms.gov/Regulations-and-Guidance/Legislation/

EHRIncentivePrograms/

Certification.html



http://oncchpl.force.com/ehrcert



https://www.cchit.org/find-onc

More on Clinical Quality Measure (CQM) Reporting

For reporting in 2013, to meet Meaningful Use when there are fewer than 6 CQMs that relate to a Radiology practice, use the following:



Report on the 3 core clinical quality measures (blood pressure, tobacco use

assessment and adult weight screening). If not all 3 measures apply to the

Radiologists’ scope of practice, then:



Report on any alternate core clinical quality measures that will bring the total

of CQMs to 3 (weight assessment/counseling for children, childhood immunization, flu immunizations for patients over 50). If the only core CQM

that applies to Radiology practice is tobacco use assessment, the Radiologist would report the numerator and denominator for that CQM, then report a “0” for all the remaining core and alternate core CQMs.



Report on any three additional clinical quality measures of the Radiologist’s

choosing.* If there is only 1 additional CQM that applies to Radiology scope of

practice (i.e., medical assistance for smoking and tobacco use cessation), the Radiologist would report the numerator and denominator for this CQM, then report a “0” for 2 additional CQMs. The Radiologist would also be required to attest to the fact that all remaining CQMs have “0” in the denominator, which would indicate that no other CQMs fit the Radiology scope of practice.

*The specific CQMs capable of being documented within an EHR vary from system to system. Discuss specific CQM reporting capabilities with your EHR vendor, system administrator and/or site manager.

Note: It has been announced that beginning in 2014, new CQMs have been added to the list of reportable measures. (For more information, visit: http://www.cms.gov/Regulations-and-Guidance/ Legislation/EHRIncentivePrograms/Downloads/Stage2_Toolkit_EHR_0313.pdf)

Meaningful Use: CORE Set Measures

(ALL 15 Required)

Suggested Methods for Radiologists

13: Clinical summaries: Clinical summaries provided to patients for

more than 50% of all office visits within 3 business days.

Exclusion: Any EP who has no office visits during the reporting period.

-Work with your EHR vendor, system administrator

and/or site manager to configure clinical summaries reporting

-Ensure clinical summaries are printed and provided to patient.

14: Exchange key clinical information: Performed at least one test of

certified EHR technology's capacity to electronically exchange key clinical information.

***No longer required for Stage 1 MU starting in 2013.***

-Work with your EHR vendor, system administrator and/or site manager to perform this test.

-This criteria will become significant in Stage 2 of MU 15: Privacy and security: Conduct or review a security risk analysis

and implement security updates as necessary and correct identified security deficiencies as part of its risk management process. Conduct or review a security risk analysis using HIPAA guidelines.

No exclusion.

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Meaningful Use Guidelines:

Radiologists

Meaningful Use MENU Set Measures:

Report on 5 of the 10 measures. Must include 1 Public Health

Reporting Measure (Measure 9 or 10).

Suggested Methods for Radiologists

1 Drug formulary checks: The EP has enabled this

functionality and has access to at least one internal or external drug formulary for the entire EHR reporting period.

Exclusion: Any EP who writes fewer than 100 prescriptions during the EHR reporting period.

-Work with your EHR vendor, system administrator and/or site manager to make sure this functionality is enabled.

-Radiologists may be exempt if they order fewer than 100 prescriptions during the reporting period. EPs must attest to the number of prescriptions written during the reporting period to qualify for exclusion.

2 Lab test results: More than 40% of all clinical lab tests results

ordered by the EP during the EHR reporting period whose results are either in a positive/negative or numerical format are incorporated in certified EHR technology as structured data.

Exclusion: Radiologists who do not order labs with test results reported as either positive/negative or numeric during the reporting period, can take an exclusion; also, lab results do not need to be electronically delivered, can be entered manually into EHR.

N/A

3 Patient list: Generate at least one report listing patients of the

EP with a specific condition. No exclusion. -Generate a list of patients with a medical condition relevant to radiology service delivery (e.g. pneumonia).

4 Patient reminders: More than 20% of all unique patients 65

years or older or 5 years old or younger were sent an appropriate preventive/follow-up care reminder during the EHR reporting period.

Exclusion: Any EP who has no patients 65 years old or older or 5 years old or younger with records maintained using certified EHR technology.

-Work with your EHR vendor, system administrator and/or site manager to configure the patient reminders.

-Ensure patient reminders are printed and provided to patient. Can use any form of reminder: calls, e-mails, postcards, etc.

5 Timely electronic access to health information: More than

10% of all unique patients seen by the EP are provided timely (available to the patient within four business days of being updated in the certified EHR technology) electronic access to their health information subject to the EP’s discretion to withhold certain information.

Exclusion: Any EP who neither orders nor creates lab tests or information that would be contained in the problem list, medication list, or medication allergy list during the reporting period.

-Check with your EHR vendor, system administrator and/or site manager about availability.

6 Patient education resources: More than 10% of all unique

patients seen by the EP during the EHR reporting period are provided patient-specific education resources.

No exclusion.

-Provide patient education materials to patient and document patient education in the EHR.

7 Medication reconciliation: The EP performs medication

reconciliation for more than 50% of transitions of care in which the patient is transitioned into the care of the EP. Exclusion: Any EP who was not the recipient of any transitions of care during the reporting period.

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Meaningful Use Guidelines:

Radiologists

Meaningful Use MENU Set Measures:

Report on 5 of the 10 measures. Must include 1 Public Health

Reporting Measure (Measure 9 or 10)

Suggested Methods for Radiologists

8

Summary of care: The EP who transitions or refers

their patient to another setting of care or provider of care provides a summary of care record for more than 50% of transitions of care and referrals.

Exclusion: An EP who neither transfers a patient to another setting nor refers a patient to another provider during the EHR reporting period.

-Record all referrals in EHR.

9

Immunization registries: Perform at least one test of

certified EHR’s capacity to submit electronic data to immunization registries and follow-up submission if the test is successful.

Exclusion: Any EP who administers no immunizations during the reporting period.

-Each EP must select one of the two public health measures (immunization registries and syndromic surveillance).

-As radiologists do not administer immunizations, this

measure is unlikely to apply to radiologists. It is acceptable to report an exclusion for this public health measure, if selected.

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Syndromic surveillance: Perform at least one test of

certified EHR’s capacity to submit electronic data to public health agencies and follow-up submission if the test is successful.

Exclusion: Any EP who does not collect any reportable syndromic surveillance information on their patients during the reporting period or does not submit such information to any public health agency that has the capacity to receive the information electronically.

-Each EP must select one of the two public health measures (immunization registries and syndromic surveillance).

-It is acceptable to report exclusion for the selected public

health measure, if applicable and documented.

-The NYC Department of Health and Mental Hygiene does have the capacity to receive the information electronically.

Looking Forward: Health Information Exchange in Stages 2 and 3 of Meaningful Use

You should be looking ahead to becoming part of a health information exchange (HIE) in New York State to allow for the sharing of your patients’ records. Connectivity to a hospital or other providers will be an important part of Meaningful Use in later years.

For more information on HIE, visit our free NYC REACH Resource Library: http://www.nycreach.org/members/

resourcelibrary. If you are interested in connecting to an HIE to exchange your records with other NYC providers, contact an NYC REACH representative for additional information.

Works Cited

American College of Radiology (ACR). Summary of Meaningful Use Rules. N.p.: American College of Radiology (ACR), 2011. Oct. 2010. Web. 6 Aug. 2013. <http://www.acr.org/~/media/ACR/Documents/PDF/Advocacy/Fed%20Relations/Meaningful%20Use/ ACRSummaryCMSandONCStage1MeaningfulUseFinalRules.pdf>.

California Primary Care Association. Dentist Crosswalk. N.p.: California Primary Care Association, n.d. California Primary Care Association. Web. 24 May 2013. <http://www.cpca.org/cpca/assets/File/Policy-and-Advocacy/Active-Policy-Issues/HIT/EHR/2012-07-17-Webinar-Dentist-Crosswalk-9-11.pdf>.

Center for Diagnostic Imaging/Merge Healthcare. Meaningful Use Guide for Radiology. N.p.: Center for Diagnostic Imaging/Merge Healthcare, 2011. Http://www.merge.com/Trends/Meaningful-Use.aspx. Center for Diagnostic Imaging/Merge Healthcare, Sept. 2011. Web. 6 Aug. 2013.

Costello, Cathy, J.D, and Herminio S. Navia, Jr. RN. "Knowing the Basics of EHR Incentive Programs." Educational Materials. American Dental Association, n.d. Web. 24 May 2013.

Dentrix/Henry Schien Dental. Facts and Myths of Meaningful Use. N.p.: Dentrix/Henry Schien Dental, n.d. Dentrix.com. Web. 24 May 2013. <http://www.dentrix.com/documents/meaningful-use/C-EXTMUFAQ-Q412.pdf>.

National Indian Health Board. EHR Incentive Program MU Measures for Dentists. N.p.: National Indian Health Board, n.d. HITECH Resource Center. Web. 24 May 2013. <http://www.crihb.org/rec/docs/EHR-Incentive-Program-Tip-Sheet_Measures-for-Dentists.pdf>.

U.S. Department of Health and Human Services. Health Resources and Services Administration. N.p., n.d. Web. 24 May 2013. <http://www.hrsa.gov/healthit/toolbox/oralhealthittoolbox/index.html>.

USA. Agency for Healthcare Research and Quality. Quality Oral Health Care in Medicaid Through. By Cheryl A. Casnoff, M.P.H., Lisa Rosenberger, M.P.H., Nancy Kwon, M.P.H., and Hilary Scherer. N.p., n.d. Web. 24 May 2013. <http://www.norc.org/PDFs/QualityOralHealthCareMedicaid[1].pdf>.

USA. Centers for Medicare & Medicaid Services (CMS). EHR Incentive Program. Stage 2 Toolkit. CMS, Feb. 2013. Web. 6 Aug. 2013. <http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/Stage2_Toolkit_EHR_0313.pdf>.

USA. CMS. Stage 2 Overview Tipsheet. N.p., n.d. Web. 31 May 2013. <https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/Stage2Overview_Tipsheet.pdf>.

USA. NYC REACH. NY Medicaid EHR Incentive Program/NYC REACH Medicaid Specialist Program. NYC REACH Resource Library, n.d. Web. 24 May 2013. <http://www.nycreach.org/>.