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CMS Guidance Could Help Radiologists Comply with ‘Meaningful Use’

The Centers for Medicare and Medicaid Services (CMS) recently published new guidance which could enhance the ability of radiologists to comply with requirements of the EHR Incentive Program, or “meaningful use.” 

A newly posted FAQ from CMS indicates that in cases where the eligible professional (EP) and the patient do not have an actual physical or telemedicine encounter, but the EP renders a minimal consultative service for the patient (the example CMS gives is a cardiologist reading an EKG), the EP may choose whether or not to include the patient in the denominator as "seen by the EP," provided the EP’s choice is consistent. Previously, the verbiage “seen by” implied that any professional service rendered by the EP (aside from those coded to inpatient and ER settings) should be included in an EP’s relevant MU measure calculations.

"The implication of this FAQ is that, for MU measures that include the 'seen by' verbiage, a diagnostic radiologist could conceivably choose to limit his/her 'seen' patients to physical visits and leave out teleradiology and similar services," said Keith J. Dreyer, DO, PhD, co-chair of ACR's IT and Informatics Committee. "There is a good amount of flexibility in the current language of this new FAQ. The key is CMS wants each EP to have a consistent policy on what services do and do not count as 'seeing' patients."

Another new FAQ from CMS indicates that when a patient is seen by the EP’s clinical staff and not by the EP themselves, the EP can elect to include or not include those patients in their denominator as long as the decision applies universally to all patients and the EP is consistent across MU measures. Previously, the implication was that patient data would be included in the MU measure calculations if any professional services were rendered by the EP, regardless of whether or not the EP physically saw the patient. The latest FAQ implies, however, that EPs can now choose to not include patients “seen by” staff and not his/herself.

Source: ACR