Rhapsody Health Solutions Team

Meaningful Use Stage 2 Requirements

Radiology & Meaningful Use Stage 2Meaningful Use Stage 2 rules were announced a few weeks ago. As the incentive program continues to roll forward, radiology’s role in Meaningful Use has always been murky. Stage 1 created confusion as to whether or not Radiologists were eligible. Although some clarity has been gained, there are still some gaps that need to be filled.

The American College of Radiology (ACR) has been leading the charge in urging the Office of the National Coordinator (ONC) of Health Information Technology to incorporate changes into Stage 2 requirements, addressing the unique attributes of radiology. Although ACR is still evaluating the Stage 2 rules, there seems to be some positive elements:

  • Computerized physician order entry (CPOE): Eligible Providers (EPs) must use CPOE to order more than 30 percent of radiology procedures during and EHR reporting period. EPs who order less than 100 imaging scans during a reporting period are exempt though.
  • Patient interaction: Since radiologists have infrequent patient interaction, it would be challenging for them to meet many of the Meaningful Use specific requirements. The Stage 2 rule allows for a hardship exemption, which provides some relief to radiologists at least until 2015.
  • Image storage: Stage 2 rules do not require an EHR to store images. A link to the images will be sufficient for now. The rule is a significant change from the initially proposed Stage 2 requirements: In the initial proposal, 40% of the patient images were required to be stored locally in the EHR. Final Stage 2 rules now require 10% of study results to be accessible via a link. The downside to this change is that it limits patient access to their images.

Some of the gaps still evident include:

  • Clinical decision support: The Stage 2 rules to do not expand the definition of CPOE to include computerized decision support (CDS). ACR has advocated greater use of CDS to curb inappropriate use of imaging.
  • Transport standards: Stage 2 rules do not address how image sets will be transferred. Although DICOM is a key standard, this is used primarily for encoding imaging sets. The Direct Project and IHE profiles, such as XDS-I and XDR-I) are options; however, sending images via secure email through the Direct Project would be challenging, and the IHE profiles are not mentioned in the Stage 2 rule.

To add perspective to the positive elements and the gaps, I’ve highlighted below several key insights from various leaders in radiology.

“I understand the initial focus of the Meaningful Use program on the broad group of practitioners who see patients in a clinic—that is the most prevalent mode of physician practice, so it is the low hanging fruit. But how information technology drives the quality of care is quite different among clinical specialties. To be effective, these incentive programs ultimately must recognize the differences.”

–Curtis Langlotz, M.D., Ph.D., vice-chair for informatics in the Department of Radiology at the University of Pennsylvania Health System in Philadelphia and a member of RSNA’s Radiology Informatics Committee (RIC).

“The involved regulatory agencies have been listening to us and modifying the federal program as best they can within the prescribed legislation parameters to accommodate our specialty’s uniqueness. Our continued involvement at this level is essential as there is no question that federal regulatory oversight of medical informatics and patient information will be a constant in our future and that Meaningful Use is just the beginning.”

–Keith Dreyer, D.O., Ph.D., vice-chair of the Department of Radiology at Massachusetts General Hospital, Boston, chair of the ACR IT and Informatics Committee-Government Relations Subcommittee and a member of RSNA’s RIC

“There seems to be an implicit assumption in the certification part of the ONC requirements, in the Stage 2 proposed rulemaking, that it’s feasible to send images, for example, by e-mail or via [the Nationwide Health Information Network’s] direct push approach, and that may not really be terribly practical.”

–David Clunie, MBBS, owner of PixelMed Publishing LLC and co-chair of the Integrating the Healthcare Enterprise (IHE) Radiology Technical Committee

As Meaningful Use continues to develop, clarity unfolds, too. ACR will, no doubt, continue to evaluate Stage 2 rules and their impact on radiology. Integrating the Healthcare Enterprise (IHE) will continue to pursue the profiles to exchange patient images efficiently and effectively. With all groups working toward the goal of productive patient data exchange with the purposeful intent of enhancing quality patient care and lowering the cost of care, good things will continue to happen.


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