10 Steps to Meaningful Use
A strategic approach helps radiologists tackle the government's incentive program.
By now, most health-care professionals have at least a basic understanding of Meaningful Use (MU) — the government program that provides incentives for the implementation and appropriate use of certified electronic health record (EHR) technology — and the impact it has on modern health-care practice.
However, despite more recent, widespread awareness of MU, confusion continues, especially among radiologists as they attempt to tackle this one-size-fits-all government program.
While the program's financial incentives have been well publicized (approximately $1 billion in maximum incentive payments for the radiology community), other concerns have also arisen. For example, consumers of imaging could become interested in knowing which individual providers and hospitals qualify for MU, and those practices may be thought to provide higher quality care than providers and institutions that fail to qualify. As a result, it is in the interest of radiologists, from a financial and practice development standpoint, to understand MU and take the appropriate steps to qualify for the program.
For diagnostic imaging professionals seeking to achieve MU, there is hope. In the radiology domain, vendors of a variety of technologies — including RIS, PACS, reporting, decision support, image sharing, patient portal, and business analytics — are actively applying for certification of their products. In fact, a number of radiology-specific certified EHR technologies already exist. However, since MU qualification requires that a practice meet a specific number of MU criteria, and because the number of certified MU criteria in each product varies, it may be necessary to combine certified products to achieve MU.
To help you find solutions and understand all aspects of Stage 1 MU, we've developed a strategic approach to meeting the challenges of this government initiative.
The 10-Step Approach: Prepare, Develop, Execute, and Sustain
Editors note: The following approach has been adapted from Part II of The Radiologist's Guide to Meaningful Use: A step-by-step approach to the Stage 1 CMS EHR Incentive Program (www.theMUguide.com).
Step 1: Understanding the Fundamentals of MU. Success begins with an understanding of the fundamentals. Build your knowledge by visiting the government program website (http://cms.theMUguide.com), attending lectures, reading articles, listening to podcasts, participating in tradeshows, or browsing the nearly 1,000 pages of regulations (http://edocket.access.gpo.gov/2010/pdf/2010-17207.pdf).
Step 2: Determining Your Eligibility and Financial Impact. Most U.S. radiologists are considered eligible professionals under the Medicare version of the incentive program. Regardless, it's a good idea to review your practice setting and group billing history to determine your incentive program eligibility and to conduct an MU analysis using your group's practice and individual "eligible professionals" (EPs) data. Preparing an analysis before developing a strategy not only helps you to better understand the impact of the incentive programs on your practice, but it also provides a baseline for internal and external MU discussions and planning. Use the tools at http://analyze.theMUguide.com to assist with this process.
Step 3: Determining Your MU Measure Requirements. The incentive program is based on individual EPs, so all radiologists at your practice may not have the same MU requirements. As a result, you need to review the individual exclusion opportunities for each radiologist. This assessment will prove invaluable in determining which of the incentive program's 25 objectives and measures your practice will need to perform and demonstrate to achieve MU. (Your group can claim exclusions for several measures based on whether EPs meet exclusion criteria.)
Step 4: Meeting With Your Practice Stakeholders. Perform an analysis of your existing imaging IT environment and meet with the MU stakeholders at your organization. Conducting an infrastructure analysis and working with others at your practice will ensure that the necessary plans are in place to be successful on your journey toward MU.
Step 5: Meeting With Your Radiology IT Vendors. At this point, you should be ready to meet with your existing radiology IT vendors and the potential IT partners who will help you achieve MU to discuss any technological requirements.
Step 6: Planning Your MU Technological and Operational Strategies. This is the point at which you begin to spend money and implement your strategy, but it is also the period when the improvements may impact your existing workflow and processes. As a result, this is the first time in the process that you may want to seek consultative assistance, which can help with budget preparation, workflow documentation, technical specifications and analysis, connectivity and data exchange, defining vendor and technology requirements, and reviewing your existing IT infrastructure. In addition to consultants, regional extension centers (RECs) have been established to help EPs as they tackle MU. (A list of RECs can be found at http://recs.theMUguide.com.) Although the RECs primarily provide assistance to eligible primary care providers in smaller practices, these centers are also a resource for all providers in a given geographic region.
Step 7: Acquiring and Implementing Certified EHR Technology. Once you have determined your operational and technological requirements, you may need to acquire or implement certified EHR technology to comply with program requirements not satisfied by your existing technology. For example, you may consider potential upgrades or add-ons to your RIS, PACS, practice management system, or any other IT platform that may be used as an EHR. Also, implementing an MU dashboard can help your group view and track all of your individual EP MU measures to ensure ongoing compliance.
Step 8: Registering Online With CMS. After obtaining your certified technology, each EP needs to register online using the Medicare and Medicaid EHR Incentive Programs Registration and Attestation System. Registration must be completed prior to submitting MU attestation. Even though registration and attestation can occur at the same time, it is advisable not to wait until your practice is ready to attest to register for the program. Although an EP can register prior to possessing all necessary certified EHR technology, this information is required before an EP can attest. Registration can be completed on the CMS website (http://register.theMUguide.com).
Step 9: Monitoring Your MU Compliance Regularly. Once you have your MU infrastructure up and running, you will need to monitor your compliance regularly against each EP's incentive program requirements. This includes implementing a tracking mechanism or dashboard and monitoring individual EP and group-level statuses. The supplier of your certified EHR technology will provide compliance dashboards for your group. In the case of a modular approach to MU, you may be required to implement a third-part solution that aggregates the data from individual systems.
Step 10: Attesting Online With CMS. Attestation, or the process of legally telling CMs than an EP has demonstrated MU of certified EHR technology, is the final step. Attestation is conducted using the same system that is used for registration — see Step 8. Prior to attesting as an EP under the Medicare program, an EP should ensure completion of these steps: 1) determine his or her eligibility to participate in the Medicare program; 2) successfully register for the Medicare program on the CMS EHR Incentive Programs Registration System; 3) meet the required number of core set, menu set, and clinical quality measures; and 4) record meeting MU criteria for the appropriate time period.
The Future of MU for Radiology
The requirements for Stage 1 MU have been established, and its set of well-defined objectives will undoubtedly act as the foundation for subsequent stages of the CMS EHR Incentive Programs. Since the Stage 1 final rule was released, health-care professionals have been tackling existing regulations in anticipation of future program requirements that expand on this groundwork by promoting quality, structured information exchange, safety, efficiency, and population health improvements.
The federal regulations surrounding future stages of the CMS EHR Incentive Programs are in a constant state of flux. With rapid changes in health-care reform, continuing education on MU initiatives will be instrumental to successfully implementing and demonstrating MU at your organization.
By Jonathon L. Dreyer and Keith J. Dreyer, D.O., Ph.D., FSIIM