Position Paper
Radiology and Meaningful Use of Healthcare IT

Background:

• Radiologists, radiology practices, and hospital radiology departments have been early-adopters of healthcare IT, investing significant amounts of time and money in radiology information systems (RIS) and picture archiving and communication systems (PACS). RIS and PACS permit the electronic sharing of images and clinical information between radiologists and other providers.
• Many radiologists work in independent practices in hospital settings. As such, they rely entirely upon their hospitals for the technology used in the performance of their clinical responsibilities (e.g., initial purchases, upgrades, and ongoing maintenance) and have little or no control over that process.
• Certain radiologists who work exclusively in hospital settings were not eligible under the proposed meaningful use rules until the Continuing Extension Act of 2010 (Pub. L. 111-157) removed the outpatient hospital setting (Place of Service = 22) from the definition of hospital-based.

Issues:

• The vast majority of current RIS/PACS products are unlikely to meet the regulatory definition of “certified EHR technology” without modifications that include all of the meaningful use criteria due to the comprehensiveness requirement in the current ONC regulations. Hospitals are pursuing electronic health record (EHR) products certified for the eligible hospital (EH) certification (Inpatient and General criteria), which are suitable for the EH version of the program, but not the eligible professional (EP) version of the program which requires a product that is certified for the Ambulatory criteria.
• Hospitals need clarification and guidance on their responsibility with respect to the physicians who practice in their hospital setting and who are eligible for the EP version of the program.
• The vast majority of the core and menu set objectives and clinical quality measurements are not relevant to the scope of a radiologist’s clinical practice. The objectives and the measures, as currently written, focus on the clinical and administrative needs of primary care and office-based providers, thus making compliance by radiologists impossibly difficult and essentially meaningless.
• The ability for a radiologist to share images real-time with an ordering physician is critical to patient care coordination.

Recommendations:

• Remove the comprehensiveness requirement such that the technology could be certified for only the measures with which the EP must comply. This would eliminate the need for the technical functionality for objectives EPs are excluded from, e.g. the e-prescribing function for the majority of radiologists.
• Require hospitals to certify for General, Inpatient, and Ambulatory criteria. This would allow EPs to use an eligible hospital’s certified EHR technology in order to qualify for Meaningful Use.
• RBMA believes meaningful use should include radiology-specific objectives and measures so that radiologists may qualify for the funds in a way that is clinically relevant to their unique role in patient care.

Conclusion:
Unless the meaningful use program is constructed in a manner that is consistent with the above recommendations, compliance would be difficult and unduly burdensome. Consequently radiologists and other specialists should not be subject to payment penalties starting in 2015.

Approved – June 6, 2011