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ACR, Radiology Associations coments to the Department of HHS regarding implementation of the Medicare/Medicaid program on meaningful use of certified EHR Technology

The American College of Radiology (ACR), American Board of Radiology, Radiological Society of North America, and the Society for Imaging Informatics in Medicine, recently submitted joint comments to the Department of Health and Human Services’ (HHS) regarding proposed implementation of the Medicare/Medicaid program on meaningful use of certified electronic health record ( EHR ) technology. The program, established by the American Recovery and Reinvestment Act of 2009, would incentivize EHR adoption by hospitals and physicians who provide services outside of hospital settings.

“Congress intended for meaningful use requirements to apply to all hospitals and all private practitioners, and to include a wide variety of technologies beyond the traditional certified comprehensive EHR products for primary care. Our comments highlighted ways the proposed program could be improved to address the needs of our patients in terms of meaningful use criteria for ordering physicians and eligible radiologists,” said Keith Dreyer, DO, PhD, ACR IT and Informatics Committee Vice Chairman and Government Relations Representative.

Initially, the program would focus on basic requirements and would expand and increase in complexity in future stages of implementation.  The proposed rule on meaningful use was accompanied by two related HHS rules—one that defines certified EHR technology (see ACR comments) and another that proposes a new certification paradigm for EHRs and other modular HIT products. Collectively, the regulations are expected to evolve approximately every two years via additional rulemakings.  After 2015, incentive payments for meaningful use will no longer be issued. Physicians outside of hospital settings who are not meaningful users would be penalized with incremental payment reductions unless exempted.  The final regulations for the first stage of meaningful use would likely be issued this summer (2010), following consideration of public comments.

“The meaningful use requirements must be modified in the final rule to be cognizant of the needs and workflows of those specialists that meet the eligibility criteria, including many radiologists. Medical imaging and radiation oncology serve an increasingly vital role in the healthcare system. The needs of radiology must be addressed in any national infrastructure in order to accomplish the broader goal of providing the best patient care possible,” said Dr. Dreyer

ACR has worked extensively with HHS, including several meetings with relevant agency staff and federal advisors, submission of written testimony and letters, and participation in numerous public and private sector conferences.  ACR also engaged with the Providers Roundtable of the Imaging e-Ordering Coalition, a group of practitioners and radiology CIOs from imaging centers who represent the primary meaningful use stakeholders from the radiology community.  The Imaging e-Ordering Coalition was originally formed to promote electronic ordering of diagnostic imaging services and the use of computerized clinical decision support tools, and its Providers Roundtable was created as a forum for stakeholders to discuss topics pertaining to meaningful use.

“Radiology is the eyes of medicine and the future of health care. It is essential for patients and their physicians to have secure and reliable electronic access to pertinent health information, including radiology reports and diagnostic images. We continue to work with the radiology community, industry partners, and federal agencies to make sure that this need is addressed,” said Khan M. Siddiqui, MD, Chair of ACR’s IT and Informatics Committee.

Source: ACR

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