March 19, 2013
Stage 2 meaningful use guidelines are finally out, and radiologists may heave a sigh of relief since most of the ambiguity that existed in Stage 1 about their eligibility and the ways to approach the qualification criterion seem to have been made amply clear by CMS and the Office of the National Coordinator (ONC). The American College of Radiology (ACR) needs word praise for its relentless effort in getting most of the necessary changes made to radiology guidelines before the Stage 2 meaningful compliance regime comes into force. While it is not before 2014 that radiologists should complying with newly laid out guidelines, it may still require some crucial adjustments in processes and technology to be fully ready for compliance and qualification under State 2 of meaningful use criterion.
Even as the Stage 2 requirements offer clarity for how computerized physician order entry (CPOE) will impact radiology, providers would still be required to use CPOE to order more than 30 percent — instead of the 60 percent CMS originally proposed — of radiology procedures during an EHR reporting period in order to qualify for MU incentive payments. Therefore, the necessity of having an efficient and effective computerized physician order entry (CPOE) would still be there.
As regards the problem of complying with the MU requirements on account of rarity of face-to-face contact with patients, radiologists and other providers may get reprieve from noncompliance penalties, but still they would be required to be versatile with specialty codes use in the Provider Enrollment Chain and Ownership System (PECOS). And this proficiency in using the Provider Enrollment Chain and Ownership System (PECOS) would definitely require specialized training or they might have to appoint external coding specialists for the purpose.
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While Stage 2 rules do not require an EHR to store images, providers or radiologist would still be required to ensure that they an active link to the images. Despite the initially proposed linkage of 40% being brought down to 10% finally, it would still be quite a task to keep those 10% active as and when required for clinical study, interpretation, or sought by patients for various documentation needs.
Along with these inherent challenges, providers or radiologists may still have to sort out the issue with employing clinical decision support (CDS) as The Stage 2 rules to do not expand the definition of CPOE to include computerized decision support (CDS). Also, there may be issues with transporting images in the absence of clear cut rules even in Stage 2. While DICOM mode can be relied upon for secure encoding images, IHE profiles, such as XDS-I and XDR-I would still have to be sent via secure email, which may sometimes be vulnerable to security and privacy threats. Therefore, it could require a dedicated monitoring to see that such files are not exposed to threats.
Amidst managing as critical a practice as radiology, complying with these set of Stage 2 guidelines for meaningful use might either be too demanding or detrimental to the very purpose of diagnostic or imaging excellence. Medicalbillersandcoders.com – with an objective to ensure diagnostic or imaging excellence unaffected by Stage 2 demands – has offered to mediate the deployment of Radiology Billing specialists that have the requisite competence and experience to implement processes and technology on behalf of radiologists, seeking to comply with the Stage 2 guidelines, and qualify for incentives.
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