Managing the Flow in Radiology

Your PACS/RIS May Be More ?Meaningful? than Ever

At long last, on July 13, 2010, CMS and the Office of the National Coordinator for Health Information Technology released the final rules for implementing Stage 1 of the Medicare/Medicaid incentive program.

These final rules define what is meant by the ?meaningful use? of certified electronic health record (EHR) technology and lay down the parameters for vendors and providers to meet those requirements.

For radiologists, the new rules mean that certain radiologists or group practices may benefit from government incentives for having implemented a RIS or PACS into their practice, but there are many prerequisites and actions by vendors to meet meaningful use standards.

You can also find relevant documents on the final rules on the ACR Web site, In addition, the ACR said that it is analyzing the rules and will be publishing more guidance on its Web site,

For now, here is a very brief analysis of how the new rules may apply to radiology group practices and individual radiologists.

Previously, there was a concern in the proposed rules that radiology would be left out of any incentives. However, Michael Peters, assistant director of regulatory and legislative portfolio, ACR Government Relations Department, stated that under the final rules, the vast majority of practicing radiologists will be eligible for incentive payments under the Medicare program.

He explained that the final rules consider physicians in outpatient hospital settings?Place of Service Code (POS) 22?to be eligible. Many radiology practices bill under POS 22.

Peters noted, ?All Medicare-participating physicians who do not provide greater than 90% of total services within an inpatient or emergency room setting (CMS POS Code 21 and 23) are eligible for the physician dollars.?

Therefore, most radiologists should be eligible for the 2% increase in Medicare reimbursement. However, aside from being eligible, radiologists must also show meaningful use of a certified EHR system or a combination of so-called ?EHR modules.?

Certified EHRs and EHR Modules

Is your radiology practice using an EHR or EHR module that qualifies under the final definition of meaningful use? The short answer is to check with your vendor. In some cases, PACS, RIS, speech recognition platforms, order/entry with decision support software, or cross-sharing software may also qualify as separate EHR modules.

Expect certification of your RIS/PACS, etc to take time?even if your vendors meet all of the meaningful use criteria. EHR modules must be certified by a CMS Authorized Testing and Certification Body (ATCB). As of this writing, it remains to be seen what organizations are chosen to be an ATCB. Once that is decided, vendors will be able to submit their products for official certification.

Also, keep in mind that whether you have a RIS, PACS, or other informatics product, each of these EHR modules is just that?a single component.

Peters explained, ?Physicians need to make sure that they have a combination of multiple certified EHR modules covering all certification criteria in the rule. So, even if a product is certified as an EHR module for one or two of the criteria, physicians still need to add other certified modules that cover the missing criteria.?

Michael Mardini, vice president of medical imaging solutions, Nuance Healthcare, Burlington, Mass, cautioned, ?There are about 25 different measures and 10 of them are core. So, if you want to get any of the stimulus money, your systems have to comply with 10 core items, and these are well documented.?

Radiologists are encouraged to contact the ACR to find out what measures are most relevant to radiologists and to their practices.

—Tor Valenza