White Paper RIS Meaningful Use Guide 201211

Meaningful Use | A Guide For Radiology
MAKING
THE MOST
OUT OF
MEANINGFUL
USE.
T H E N E W B E N C H M A R K I N H E A L T H C A R E I T.
Meaningful Use | A Guide for Radiology
Table of Contents
Chapter 1: Meaningful Use Legislation and its Impact on Healthcare.................................................................................... 4
Meaningful Use Defined.............................................................................................................................................................. 4
Electronic Patient Records ........................................................................................................................................................... 4
Goals of Meaningful Use............................................................................................................................................................. 4
Medicare and Medicaid Programs ............................................................................................................................................... 5
About Stage 1 Meaningful Use ................................................................................................................................................... 6
About Stages 2 and 3 ................................................................................................................................................................. 6
Chapter 2: Meaningful Use Legislation...................................................................................................................................... 6
A Brief History of How We Got Here ........................................................................................................................................... 6
Federal Agencies ......................................................................................................................................................................... 6
Chapter 3: Incentives and Penalties ........................................................................................................................................... 8
Incentives Available for Meaningful Use ...................................................................................................................................... 8
The Penalties for Noncompliance ................................................................................................................................................ 9
Receiving Your Incentive Payment ............................................................................................................................................... 9
Chapter 4: Meaningful Use Measures for Radiology.............................................................................................................. 10
Overview................................................................................................................................................................................... 10
Core Set.................................................................................................................................................................................... 10
Vue RIS and Core Set Measures ................................................................................................................................................ 12
Menu Set .................................................................................................................................................................................. 12
Vue RIS and Menu Set Measures............................................................................................................................................... 15
Clinical Quality Measures (CQMs).............................................................................................................................................. 15
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Chapter 5: Certified Technology............................................................................................................................................... 16
Certified EHR Technology.......................................................................................................................................................... 16
Complete vs. Modular EHR Certification.................................................................................................................................... 16
Chapter 6: Radiologists and Meaningful Use .......................................................................................................................... 17
Eligibility ................................................................................................................................................................................... 17
Financial Impact to Your Organization....................................................................................................................................... 17
Incentive Payments and Medicare Thresholds ............................................................................................................................ 17
More about Incentive Payments ................................................................................................................................................ 18
Chapter 7: Developing Your Strategy...................................................................................................................................... 18
Where to Begin? ....................................................................................................................................................................... 18
Suggested Steps to Achieving Meaningful Use .......................................................................................................................... 20
Chapter 8: Workflow Changes and Considerations................................................................................................................ 21
Review and Document Your Current Workflow......................................................................................................................... 21
“Seen by the EP” ...................................................................................................................................................................... 21
Areas Where Workflow May Change ........................................................................................................................................ 22
Workflow Considerations.......................................................................................................................................................... 22
Chapter 9: Meaningful Use and Vue RIS.................................................................................................................................. 24
How Vue RIS Helps You with Meaningful Use ........................................................................................................................... 25
Vue RIS and Measure Certification ............................................................................................................................................ 26
Vue RIS and Data Capture......................................................................................................................................................... 28
Chapter 10: Attestation............................................................................................................................................................. 34
Attestation................................................................................................................................................................................ 34
Before You Begin ...................................................................................................................................................................... 34
Attestation Steps....................................................................................................................................................................... 34
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Chapter 11: What's Next? ......................................................................................................................................................... 49
Looking Forward to Stage 2 ...................................................................................................................................................... 49
Stage 2 High-Level Overview ..................................................................................................................................................... 49
In Summary............................................................................................................................................................................... 49
Appendix 1: Resources .............................................................................................................................................................. 50
Appendix 2: Works Cited .......................................................................................................................................................... 50
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electronic health records (EHR) and demonstrate compliance
Chapter 1: Meaningful Use with their certified EHR technology through a series of
Legislation and its Impact on measures and quality outcomes. Additionally, incentives were
established as part of the program to encourage adoption, as
Healthcare well as penalties starting in 2015 for non-compliance.
Meaningful Use (MU) legislation is proving to be a challenge
for healthcare facilities nationwide. Today, “meaningful use” is Electronic Patient Records
one of the most talked-about initiatives facing healthcare, One of President Obama’s key healthcare initiatives was to
along with the associated capture and exchange of patient encourage healthcare facilities and providers to capture and
information. The ongoing development of this legislation will share key clinical data on all patients in an overall attempt to
have a great impact on healthcare with regard to patient- improve clinical quality outcomes and ultimately lower the cost
information access, today and well into the future. of patient care.
Understanding what Meaningful Use means to your
organization and how it impacts your business, financially and Part of the American Recovery and Reinvestment Act (ARRA) of
from a workflow perspective, will be key drivers not only for 2009 and the Health Information Technology for Economic
your continued success, but also for your compliance with this and Clinical Health Act (HITECH) offers incentives to eligible
program. providers (EPs) of up to $44,000 for Medicare and $63,750 for
Medicaid, providing they can show they are “certified” users
Recognizing the confusion surrounding this initiative, of electronic health records within a specified timeframe.
Carestream Health has put together this guide to provide you
with a better understanding of MU and how it applies Still in its early phases, Meaningful Use is requiring physicians
specifically to radiology. It’s also intended to demonstrate how and healthcare facilities to quickly understand complex
using our solutions will help ensure your continued compliance legislation and begin to adopt certified technology. The
as further stages of MU are rolled out. With over $1.5 billion challenge has been for specialists, since the Meaningful Use
available in incentive payments to adopt and use meaningful program in stage 1 does not offer much flexibility for their
data in the United States, each eligible professional – including compliance, yet they are being held to the same penalties as
over 90% of all radiologists – can participate and receive up general practitioners.
to $44,000 in incentive dollars before 2015.
The Meaningful Use Program is moving ahead, but has been
It’s also important to understand what’s at stake. Whether or divided into stages with a clear trajectory for its overall
not you choose to participate, there will be Medicare penalties implementation. Stage 1 of Meaningful Use focuses on the
and quite possibly commercial payer penalties that could collection and sharing of patient data; Stage 2 focuses on
directly impact your organization if you choose not to clinical decision support; and Stage 3 focuses on improving
participate by 2015. patient outcomes.
The goal of this guide is to help you to better understand this We are well underway with Stage 1 of Meaningful Use and in
initiative and overall complexities you will most likely face as February 2012, the criteria for Stage 2 was released by the
you and your personnel deploy Meaningful Use at your facility. CMS for public comment, with the final measures released in
It by no means covers every conceivable question you may August 2012.
have, but will lay the groundwork to help you more effectively
understand and plan your MU goals. Finally, this guide will Goals of Meaningful Use
focus on the Medicare version of Meaningful Use, not the
Medicaid version of the program. One of the primary goals of the Meaningful Use (MU) Program
is to not only adopt and implement certified EHR technology,
Meaningful Use Defined but to also use EHR technology to achieve health and
efficiency goals. These five primary healthcare goals are to:
The term “Meaningful Use” refers to the use of certified
electronic health record technology and the exchange of • Improve quality, safety and efficiency while reducing
patient information among healthcare professionals. The health disparities
Meaningful Use Program was designed to encourage
healthcare providers to purchase and implement certified • Engage patients and families in their healthcare
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• Promote and improve public and population health Medicare and Medicaid Programs
• Improve care coordination between providers There are two versions of the Meaningful Use Program
available to satisfy Medicare and Medicaid providers, but an
• Ensure adequate privacy and security protections for eligible provider can only choose to participate in one version.
personal health information Eligibility variances exist for both versions, but most
To meet MU goals, a user must meet a series of objectives that radiologists will fall in the Medicare version of the program.
use EHR’s capabilities and are directly related to the The biggest difference between the programs is the financial
improvement of quality, efficiency and patient safety incentive available: $44,000 per eligible provider (EP) over five
throughout the healthcare system. [Dreyer, Jonathon L. and years for Medicare vs. $63,750 per EP over six years for
Keith J. Dreyer, "Goals of Meaningful Use." The Radiologist's Medicaid.
Guide to Meaningful Use. Michigan: RMU Press, 2011. 23.
Print.] The table below provides the differences between the two
versions of the program:
Medicare Medicaid
Eligible Entities Medical professionals, hospitals, and critical access hospitals Medical professionals, nurse
practitioners, certified nurse-midwives,
Hospital-based professionals are not eligible (90% of services are dentists, and physician assistants
preformed in a hospital inpatient or emergency setting)
Incentive Payments Up to $44,000 per EP over 5 years Up to $63,750 per eligible provider
over 6 years
Are 75% of allowed Medicare physician fee charges up to variable
yearly limits Payment based on patient volume
Only based on professional service charges, not technical fees Payments are flat amounts per year
Participation in only 1 of the 2 eligible programs 30% of patients must be Medicaid
Timing Available in 2011 Begins in 2011, depending on state law

Begin 2012 to receive maximum payments Must begin by 2016
Required by 2015; penalties apply after 2015
Must show 90 consecutive days of meaningful use in first reporting
year and report full years thereafter
Non-participation Starting in 2015, without hardship exemption, Medicare No loss of Medicaid reimbursement for
reimbursements reduced 1% per year to a 5% maximum non-compliance
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About Stage 1 Meaningful Use Chapter 2: Meaningful Use

Stage 1 sets the stage for the Meaningful Use program by
setting guidelines for capturing clinical health information
Legislation
and using that data to track and communicate patient A Brief History of How We Got Here
conditions. This first phase identifies the measures that are
specific to eligible hospitals (EHs) and eligible professionals Close to four years ago, President Obama committed to
(EPs). computerizing our nation’s healthcare records over a five-
year period, with the intent to lower costs, cut medical errors
Radiologists that qualify as EPs under the Medicare version and improve overall patient outcomes. Congress passed the
of MU must report against 15 Core Set Objectives, 10 Menu American Recovery and Reinvestment Act of 2009 (ARRA),
Set Objectives, and 44 Clinical Quality Measures. Each set of which is now an $840+ billion piece of legislation signed
measures includes specific objectives, some of which may be into law. A significant portion of this legislation created the
excluded based on an eligible provider’s scope of practice. Health Information and Technology for Economic and
[Dreyer, Jonathon L. and Keith J. Dreyer, "Stage 1 Clinical Health (HITECH) Act, which was designed to
Meaningful Use." The Radiologist's Guide to Meaningful promote the adoption of electronic health records and to the
Use. Michigan: RMU Press, 2011. 24. Print.] (There are eight use of patient data in a meaningful way. About $20 billion
additional criteria related to data security that software was set aside to use as incentives toward modernizing our
vendors must adhere to in addition to the 25 measures healthcare informatics systems, which is now being deployed
required for EPs.) All criteria can be obtained in a single EHR nationwide. [Dreyer, Jonathon L. and Keith J. Dreyer, "The
or other software solution that is classified as a complete American Recovery And Reinvestment Act (ARRA) and
EHR for Stage 1 MU; or all criteria can be obtained through Health Information and Technology For Economic and
multiple solutions that are classified as an EHR module for Clinical Health (HITECH) Act." The Radiologist's Guide to
Stage 1 MU and fulfill the required measures to equal a Meaningful Use. Michigan: RMU Press, 2011. 30. Print.]
complete EHR. See the next section for detailed descriptions
of these measures. The Continuing Extension Act of 2010 was passed in April
2010,--removing “outpatient” from the hospital-based
About Stages 2 and 3 definition of the legislation. This act is what now classifies
the majority of radiologists, as well as other specialists, as
Stage 2 final Meaningful Use criteria was released in August eligible participants in the incentive program – but keep in
2012 and contains measures that begin to focus more on mind this also holds them to the penalties that will begin in
specialty practices, including radiology, such as: 2015 for noncompliance. Final Stage 1 rules were issued in
July 2010 along with an initial set of EHR testing and
• The implementation of medical images into EHRs certification groups (Certification Commission for Health IT -
CCHIT; Drummond Group - DGI; InfoGard Laboratories;
• Loosening the requirement to “possess” all ICSA Labs; SLI Global Solutions; and Surescripts). [Dreyer,
measures that you are excluded from Jonathon L. and Keith J. Dreyer, "The Interim Final Rule (IFR)
and Notice of Proposed Rulemaking (NPRM)." The
Implementation of Stage 2 is anticipated to begin in 2014. Radiologist's Guide to Meaningful Use. Michigan: RMU
Note that although the measures have relaxed for Stage 2, Press, 2011. 31. Print.]
EPs will still be required to meet the Stage 1 criteria before
proceeding to Stage 2. In other words, an EP can't "jump" Federal Agencies
into Stage 2 in 2012 without first complying with Stage 1.
Two federal agencies oversee the Meaningful Use legislation
Furthermore, an EP must begin their
and hold joint responsibility for its implementation and
development: the CMS - Centers for Medicare and Medicaid
Stage 3 will focus more on improved patient outcomes,
Services, and the ONC - Office of the National Coordinator.
improvement in data exchange between public health
Both agencies fall under the Department of Health and
agencies, and build on stage 2.
Human Services.
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The CMS holds the responsibility for regulating how the It should be noted that future public comment, rulemaking,
technology is used (specifically monitoring the eligible legislation, and overall needs will help shape future stages of
providers) while the ONC is responsible for defining and Meaningful Use as it continually evolves. One should look at
regulating the technology itself (the vendors and products Meaningful Use as not a defined set of standards all
submitted for certification). healthcare providers will be required to meet but an
evolution of a defined path to improving patient outcomes
For Stage 1 Meaningful Use, healthcare providers must and lowering healthcare costs though technology and access
comply with 25 objectives and measures issued by the CMS. to key patient information.
The ONC identified an additional 8 measures beyond the
core 25 for a total of 33 certification criteria that all software
vendors must certify against (the additional 8 measures
adhere to privacy, security, and access capabilities and
logging). Compliance of all 33 criteria by a software vendor
allows them to be certified as a “complete” EHR, regardless
of the solution (in other words, a RIS, lab, or any other IT
system that meets all 33 stage 1 criteria, plus can report the
minimum required clinical quality measures, and passes
certification would be considered a complete EHR). If a
vendor submits their software for testing and passes any of
the certification criteria, but not all 33 criteria, they would be
certified as an “EHR module,” meaning the solution satisfies
some, but not all, 33 (any vendor obtaining certification
must pass the 8 required security and privacy criteria as well
to receive modular certification). The table below
summarizes what the two agencies regulate:
CMS ONC
Specifies criteria that eligible Sets standards, implementation

professionals (EPs), eligible guidelines, and criteria required for
hospitals (EHs), and critical-access certification and ongoing
hospitals (CAHs) must meet to certification of EHRs by
demonstrate meaningful use and participating vendors that will be
qualify for incentive payments used by EPs and EHs
Sets Core and Menu Set criteria Coordinates the standards required
that all providers must meet to of EHR systems with the MU
receive incentive payments requirements that must be met by
EPs of EHs
Provides ongoing guidance and Complying with the established

establishes rules and criteria to standards, EPs and EHs can be
phase in the Meaningful Use assured that the certified
Program over time based on technology they purchase will
available technology today plus allow their chosen certified EHR to
overall practice experience meet the requirements put forth
by the CMS
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first year. This means a site must be live and collecting the
Chapter 3: Incentives and data it will report for each eligible professional participating
Penalties in the program by October 3, 2012 in order to receive full
credit for year one of the Medicare EHR Incentive Program).
Incentives Available for Meaningful Use Post year one, reporting must be for the full 12 calendar
One of the key drivers rapidly pushing healthcare facilities months.
and eligible professionals to adopt Meaningful Use is the
large incentives in place to help offset the costs involved in Eligible professionals who provide at least 50% of their
the adoption of electronic health records, both at the services in a designated Health Professional Shortage Area
provider and state levels. (HPSA) may qualify for an additional 10% bonus payment
for each year of successful program participation. HPSA
All eligible professionals who comply with certified EHR areas are designated by the US Department of Health and
technology are eligible to receive up to a total of $44,000 in Health Resources and Services Administration (HRSA) due to
incentive payments over a five-year period, based on the shortages of primary medical care, dental or mental health
year in which they begin participating in the Medicare EHR providers. These areas may qualify due to geographic or
Incentive Program. (The facilities or professionals who demographic considerations (high poverty, high elderly
participate in the Medicaid Incentive Program will be eligible concentration, high infant mortality rates, or too few primary
to receive up to $63,750 in incentive payments over a six- providers). [Dreyer, Jonathon L. and Keith J. Dreyer,
year period, based on the year they participate in the "Meaningful Use Program Incentives" The Radiologist's
Medicaid EHR Incentive Program. As stated earlier, this guide Guide to Meaningful Use. Michigan: RMU Press, 2011. 40.
focuses on the Medicare Incentive Program. Print.]
For calendar years 2011-2016, eligible professionals who The table below shows a summary of the incentive payments
participate in the Medicare Incentive Program must start available to eligible professionals under the Medicare EHR
with reporting 90 days of consecutive use of meaningful Incentive Program:
data in order to receive the full incentive payment for the
Calendar Year 2011 2012 2013 2014 2015+
2011 Up to $18,000 ---- ---- ---- $0
2012 Up to $12,000 Up to $18,000 ---- ---- $0
2013 Up to $8,000 Up to $12,000 Up to $15,000 ---- $0
2014 Up to $4,000 Up to $8,000 Up to $12,000 Up to $12,000 $0
2015 Up to $2,000 Up to $4,000 Up to $8,000 Up to $8,000 $0
2016 ---- Up to $2,000 Up to $4,000 Up to $4,000 $0
Total Up to $44,000 Up to $44,000 Up to $39,000 Up to $24,000 $0
Source: Centers for Medicare and Medicaid Services
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The Penalties for Noncompliance but they will also not be eligible for the incentives either.
Stage 2 further defines these hardship exemptions.
While there are some very attractive incentives available to
eligible providers for complying with Meaningful Use criteria, For all eligible providers, including many radiologists, there
there are also penalties (or payment adjustments) that will are hundreds of millions of dollars at stake if practitioners
take place for failure to comply. The payment adjustments ignore Meaningful Use legislation. If private payers decide to
will go into effect in 2015 and will continue through 2019 apply the same penalties, the cumulative amount could be
and possibly beyond. The latest information on these collectively extensive.
penalties shows they ultimately are significant and could
adversely affect the profitability of a practice that relies on a
good portion of their revenue from Medicare. What has
Receiving Your Incentive Payment
many providers concerned is whether private payers will also We’ll discuss attestation towards the end of this guide, but
decide to enforce the same level of penalties. Overall, this once your practice has determined your eligibility and you’ve
could be a significant reduction in the amount of revenue a decided you will participate in the EHR Incentive Program,
provider receives. The bottom line: most facilities will have each EP needs to do the following:
little choice but to adopt and adhere to the Meaningful Use
Program, and the sooner they get started, the better position 1. Obtain a National Provider Identifier (NPI).
they’ll be in as the program matures over the next few years.
The table below outlines the payment reductions (penalties) 2. Enroll in the Centers for Medicare and Medicaid
in Medicare payments that practices could anticipate for Services (CMS) Provider Enrollment Chain and
noncompliance with the Meaningful Use Program: Ownership System.
3. Create an account in the National Plan and Provider
Enumeration System.
Calendar Payment Reduction

Once EPs have met the requirements outlined in the
Year Medicare version of the incentive program, they must
demonstrate that they are applying Meaningful Use on the
CMS online Registration and Attestation System. [Dreyer,
2015 Minus 1% of total Medicare fee schedule Jonathon L. and Keith J. Dreyer, "Meaningful Use Incentive
compensation Payments." The Radiologist's Guide to Meaningful Use.
Michigan: RMU Press, 2011. 43. Print.]
2016 Minus 2% of total Medicare fee schedule
compensation As an EP, you’ll use this system to provide your numerators
and denominators for each Core, Menu, and Clinical Quality
Measure you are tracking. This attestation is your legal
2017 Minus 3% of total Medicare fee schedule obligation to the CMS, which is required prior to receiving
compensation your incentive payment.
2018 Minus 3%, or minus 4% if > 75% of EPs are After successful attestation within the CMS system you will
not demonstrating meaningful use be eligible to receive a single payment each year you
participate in the Medicare EHR Incentive Program. In
subsequent years, the attestation process will require you to
2019+ Minus 3%, or minus 5% if > 75% of EPs are submit your numerators and denominators to the CMS
not demonstrating meaningful use electronically through your certified EHR program. Providers
participating in the HPSA program will receive an additional
Source: Centers for Medicare and Medicaid Services separate payment each year of program participation.
There are annual hardship exemptions as well, which will be
reviewed on a case-by-case basis, and these could relieve
some EPs from the payment adjustments for up to five years
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Chapter 4: Meaningful Use Core Set

There’s a total of 15 Core Set Measures, which are
Measures for Radiology mandatory for all eligible providers to comply with,
Overview regardless of specialty or practice scope. However, there are
exclusions you may be eligible for within your practice. Either
The goals behind Stage 1 of Meaningful Use are to adopt way, even with the exclusions, recall that you still must
electronic health record (EHR) technology and capture key "possess" the capability (Note: Certified EHR technology
clinical data on patients. To do this, the CMS has identified “possession” requirements change beginning in 2014). But
25 Core and Menu Set Objectives to capture as well as 44 since you’re reading this, most likely you’re installing
specific Clinical Quality Measures to report against. In the Carestream’s RIS – which means you’ll meet full compliance
next section, we’ll explore each of these, their exclusions, on all Core measures. Below are the 15 Core Measures, their
and the measures that typically make the most sense for requirements, along with the Measures that are applicable
radiologists to comply with. Note that these are provided as for exclusion:
guidelines and only your practice can determine which
measures make the most sense for you to track and report
for your eligible providers (EPs).
Objective Measure Exclusion
42 CFR §495.6(d)(1) More than 30% of unique patients with at least one Any EP who writes fewer than
medication in their medication list seen by the EP have at 100 prescriptions during the
Use computerized provider order entry (CPOE) least one medication order entered by CPOE EHR reporting period
for medication orders directly entered by any
licensed health care professional who can enter
orders into the medical record per state, local,
and professional guidelines
42 CFR §495.6(d)(2) The EP has enabled this functionality for the entire EHR N/A
reporting period
Implement drug-drug and drug-allergy
interaction checks
42 CFR §495.6(d)(3) More than 80% of all unique patients seen by the EP N/A
have at least one entry or an indication that no problems
Maintain an up-to-date problem list of current are know for the patient recorded as structured data
and active diagnoses
42 CFR §495.6(d)(4) More than 40% of all permissible prescriptions written Any EP who writes fewer than
by the EP are transmitted electronically using certified 100 prescriptions during the
Generate and transmit permissible prescriptions EHR technology EHR reporting period
electronically (eRx)
have at least one entry (or an indication that the patient
Maintain an active medication list is not currently prescribed any medication) recorded
structured data.
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have at least one entry (or an indication that the patient
Maintain active medication allergy list has no known medication allergies) recorded as
structured data
42 CFR §495.6(d)(7) More than 50% of all unique patients age 2 and over N/A
seen by the EP have demographics recorded as
Record demographics: preferred language, structured data
gender, race, ethnicity, date of birth
42 CFR §495.6(d)(8) More than 50% of all unique patients age 2 and over Any EP who either sees no
seen by the EP have height, weight, and blood pressure patients age 2 or older, or who
Record and chart changes in vital signs: height, recorded as structured data believes that all three vital signs
weight, blood pressure. Calculate and display of height, weight, and blood
BMI, plot and display growth charts for children pressure of their patients have
2-20 years (including BMI). no relevance on their scope of
practice
42 CFR §495.6(d)(9) More than 50% of all unique patients 13 years old and Any EP who sees no patients
older seen by the EP have smoking status recorded as 13 years and older
Record smoking status for patients 13 years structured data
old or older
42 CFR §495.6(d)(10) For 2011, provide aggregate numerator and N/A

denominator, and exclusions through attestation as
Report ambulatory clinical quality measures to required by CMS and for 2012, electronically submit the
CMS or the States CQMs as required by CMS
42 CFR §495.6(d)(11) Implement one clinical decision support rule N/A

Implement one clinical decision support rule
relevant to specialty or high clinical priority
along with the ability to track compliance with
that rule
42 CFR §495.6(d)(12) More than 50% of all patients who request an electronic Any EP that has no requests
copy of their health information are provided it within from patients of their agents for
Provide patients with an electronic copy of their three business days an electronic copy of patient
health information (including diagnostic test health information during the
results, problem list, medication lists, EHR reporting period
medication allergies) upon request
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42 CFR §495.6(d)(13) Clinical summaries provided to patients for more than Any EP who has no office visits
50% of all office visits within three business days during the EHR reporting period
Provide clinical summaries for patients for each
office visit
42 CFR §495.6(d)(14) Performed at least one test of certified EHR technology’s N/A
capacity to electronically exchange key clinical
Capability to exchange key clinical information information
(for example: problem list, medication list,
medication allergies, diagnostic test results)
among providers of care and patient
authorized entities electronically
42 CFR §495.6(d)(15) Conduct or review a security risk analysis per 45 CFR N/A
164.308(a)(1) and implement security updates as
Protect electronic health information created or necessary and correct identified security deficiencies as
maintained by the certified EHR technology part of its risk management process
through the implementation of appropriate
technical capabilities
Vue RIS and Core Set Measures latter uses an integration with the DrFirst e-prescribing
solution).
Since all core set measures are required and may not be
entirely applicable to radiology, they will provide some
Menu Set
practice benefits beyond receiving an incentive payment,
such as: better structured data capture, improved practice- In addition to the 15 Core Set Measures, there are a set of
management capabilities, and better data maintenance Menu Set Measures that must also be embraced to achieve
within your IT infrastructure. Later in this guide, we’ll discuss meaningful use. All EPs are required to report on five out of
ways to review your practice to determine your exclusion these additional 10 measures, except when exclusion criteria
eligibility for specific Core items, keeping in mind that you are met. If EPs meet the exclusion criteria for one Menu Set
still must possess the technology and have the capability to Measure, they must choose four out of the remaining nine
capture the data, even if you opt to exclude capturing some measures; if they qualify for two Menu exclusions, they must
data. select three out of the remaining eight measures, and so on.
CARESTREAM Vue RIS has the capability to satisfy all of the Note: Beginning in 2014, Stage 1 Menu Set reporting
required Core Set Measures for your practice. Carestream is specifications change. Refer to the CMS Stage 2 Final Rule
currently planning our development objectives and market for more information. [Dreyer, Jonathon L. and Keith J.
deliverables to continue our certification process as the Dreyer, The Radiologist's Essentials to Meaningful Use:
industry moves from Stage 1 to Stage 2 to make sure we Essentials for Your First 2 Years. Michigan: RMU Press, 2012.
meet our customer's required needs as they continue to Print.]
implement and deploy their meaningful use strategy. To
The following table lists the Menu Set Measures and their
date, CARESTREAM Vue RIS has obtained complete
exclusions:
certification for Stage 1, including e-prescribing, drug/drug,
drug formulary, and drug/allergy interaction checks (the
12
42 CFR §495.6(e)(1) The EP has enabled this functionality and has Any EP who writes fewer than 100
access to at least one internal or external prescriptions during the EHR reporting
Implement drug-formulary checks formulary for the entire EHR reporting period period
42 CFR §495.6(e)(2) More than 40% of all clinical lab tests results An EP who orders no lab tests whose
ordered by the EP during the EHR reporting results are either in a positive/negative or
Incorporate clinical lab test results into period whose results are either in a numeric format during the EHR reporting
certified EHR technology as structured data positive/negative or numerical format are period
incorporated in certified EHR technology as
structured data
42 CFR §495.6(e)(3) Generate at least one report listing patients of N/A

the EP with a specific condition
Generate lists of patients by specific
conditions to use for quality improvement,
reduction of disparities, research, or outreach
42 CFR §495.6(e)(4) More than 20% of all unique patients 65 years An EP who has no patients 65 years or
or older of 5 years old or younger were sent an older of 5 years old or younger with
Send reminders to patients per patient appropriate reminder during the EHR reporting records maintained using certified EHR
preference for preventive/follow-up care period technology
42 CFR §495.6(e)(5) More than 10% of all unique patients seen by Amy EP that neither orders nor creates
the EP are provided timely (available to the any of the information listed at 45 CFR
Provide patients with timely electronic access patient within four business days of being 170.304(g) during the EHR reporting
to their health information (including lab updated in the certified EHR technology) period
results, problem list, medication lists, electronic access to their health information
medication allergies) within four business days subject to the EP’s discretion to withhold certain
of the information being available to the EP information
42 CFR §495.6(e)(6) More than 10% of all unique patients seen by N/A
the EP during the EHR reporting period are
Use certified EHR technology to identify provided patient-specific education resources
patient-specific education resources and
provide those resources to the patient if
appropriate
42 CFR §495.6(e)(7) The EP performs medication reconciliation for An EP who was not the recipient of any
more than 50% of transitions of care in which transitions of care during the reporting
The EP who receives a patient from another the patient is transitioned into the care of the EP period
setting of care of provider of care of believes
an encounter is relevant should perform
medication reconciliation
13
42 CFR §495.6(e)(8) The EP who transitions their patient to another An EP who neither transfers a patient to
setting of care or provider of care provides a another setting nor refers a patient to
The EP who transitions their patient to summary of care record for more than 50% of another provider during the EHR
another setting of care of refers their patient transitions of care and referrals reporting period
to another provider of care should provide
summary of care record for each transition of
care or referral
42 CFR §495.6(e)(9) Performed at least one test of certified EHR An EP who administers no immunizations
technology’s capacity to submit electronic data during an EHR reporting period or where
Capability to submit electronic data to to immunization registries and follow up no immunization registry has the capacity
immunization registries or Immunization submission if the test is successful (unless none to receive the information electronically
Information Systems and actual submission in of the immunization registries to which the EP
accordance with applicable law and practice submits such information have the capacity to
receive the information electronically)
42 CFR §495.6(e)(10) Performed at least one test of certified EHR An EP who does not collect any
technology’s capacity to provide electronic reportable syndromic information on
Capability to submit electronic syndromic syndromic surveillance data to public health their patients during the EHR reporting
surveillance data to public health agencies agencies and follow-up submission if the test is period or does not submit such
and actual submission in accordance with successful (unless none of the public health information to any public health agency
applicable law and practice agencies to which an EP submits such that has the capacity to receive the
information have the capacity to receive the information electronically
information electronically)
14
Vue RIS and Menu Set Measures • NFQ 0028 - Tobacco Use Assessment and
Cessation Intervention: Percentage of patients
Vue RIS provides the ability for your practice to meet all 10
(over age 18) seen at least two times who were
Menu Set Measures providing your radiology practice better
asked about tobacco use within a 24-month period;
opportunity to meet program requirements. It is important
or the percentage of patients over age 18 who were
that you analyze your practice to determine what measures
known tobacco users and were seen two times
you are excluded from and what ones, you will comply with.
within a 24-month period after receiving cessation
Even with full exclusion of the Menu Set Measures, you will
intervention.
still be required to submit electronic syndromic surveillance
data or immunization records but this capability is supported • NFQ 0421/PQRI 128 - Adult Weight Screening
by Vue RIS, allowing you to comply with the Menu Set and Follow-up: Percentage of patients over age 18
requirements. with a calculated BMI documented in their medical
record, current visit or within the previous six
Clinical Quality Measures (CQMs) months where the BMI falls outside the standard
parameters, and the patients have documented
In addition to meeting the Core and Menu Set Measures, follow-up plans.
your EPs must submit Clinical Quality Measures based on the
measures you are tracking. Failure to submit CQMs will The following are some samples of discretionary CQMs you
demonstrate non-compliance in the incentive program and may wish to track due to their simplicity (yes/no responses)
cause you to not receive your incentive payment. There are a and relevance to radiology EPs:
total of 44 CQMs available to track and submit. However, a
radiology EP will only need to submit six CQMs: three • NFQ 0043/PQRI 111 - Pneumonia Vaccination
core/alternate core and three discretionary (a total of 9 Status for Older Adults: Percentage of patients
CQMs are available to choose from to submit within Vue over age 65 who have ever received pneumococcal
RIS). Many of the measures have percentage-based vaccine.
requirements you must follow and you’ll need to track your
numerators (overall population seen by the EP) and • NFQ 0031/PQRI 112 - Breast Cancer Screening:
denominators (number of patients seen where you are Percentage of woman 40-69 who have had a
tracking a specific measure). The calculation of the mammogram to screen for breast cancer.
denominator into the numerator allows you to see if you’ve • NFQ 0034/PQRI 113 - Colorectal Cancer
met the threshold required for compliance with any specific Screening: Percentage of adults ages 50-75 who
CQM measure you want to submit. If an EP has a zero have had a screening for colorectal cancer.
denominator for a core or alternate core CQM, he or she still
meets compliance for that measure by reporting a zero. Note: CQM reporting requirements will change beginning in
2014, regardless of the stage of meaningful use. [Dreyer,
What CQMs you submit will be based on the ones your Jonathon L. and Keith J. Dreyer, The Radiologist's Essentials
certified EHR solution offers for you and your individual to Meaningful Use: Essentials for Your First 2 Years.
practice. Some may meet all 44 CQMs while some may only Michigan: RMU Press, 2012. Print.]
offer a handful to choose from. For those solutions that
offer only a few CQMs to submit, keep in mind that the
vendor has most likely determined these CQMs apply most
to the field of radiology and will require the lease amount of
disruption to your workflow to capture and track throughout
a reporting period. Based on most diagnostic radiology
practices, below is the list of core CQMs you’ll most likely
track and submit for Stage 1:
• NFQ 0013 - Hypertension Blood Pressure

Measurement: Percentage of patient visits (over
age 18) with a diagnosis of hypertension; seen at
least two times with a recorded blood pressure
15
EHR technology must meet in order to address privacy and
Chapter 5: Certified Technology security. These (plus an optional ninth) criteria are listed
below:
Certified EHR Technology
As previously mentioned, the use of certified EHR technology • 45 CFR §170.302(o): Access control
is administered by the Office of the National Coordinator for • 45 CFR §170.302(p): Emergency access
Health IT (ONC). The ONC has established a temporary
certification program to authorize organizations to test and • 45 CFR §170.302(q): Automatic log-off
certify healthcare IT vendors’ technology. The ONC has
established the criteria for certification and these testing • 45 CFR §170.302(r): Audit log
bodies ensure that EHRs are capable of meeting Stage 1 • 45 CFR §170.302(s): Integrity
Meaningful Use criteria for 2011-2012. Recently, the ONC
extended the temporary program to allow the Authorized • 45 CFR §170.302(t): Authentication
Testing and Certification Bodies (ONC-ATCB) to continue to • 45 CFR §170.302(u): General encryption
test and offer EHR certification.
• 45 CFR §170.302(v): Encryption when exchanging
The goal behind this program was to assure that certified electronic health information
technology would be available for EPs and EHs that complied
• 45 CFR §170.302(w - optional): Accounting of
with Meaningful Use and allow EPs to collect their incentive
disclosures
payments, beginning in 2011. [Dreyer, Jonathon L. and Keith
J. Dreyer, "Temporary EHR Certification Program." The Modular certification refers to a vendor that has passed at
Radiologist's Guide to Meaningful Use. Michigan: RMU least one of the 25 required measures – Core or Menu, plus
Press, 2011. 70. Print.] the eight security and privacy measures. Complete
certification refers to a vendor that has passed all 25
Just for reference, the following is the list of Authorized measures, plus the eight security and privacy measures. If
Testing and Certification Bodies you may hear about. A your practice chooses to use modular technology, the CMS
vendor that has been certified by any one of these testing has created a tool to help you select your technology and
bodies meets the criteria as a modular EHR or complete EHR, place it in a “basket” (like a shopping cart on any website).
based on its testing outcome. A product that has been Once you add your technology solutions, you can view your
certified by any of the following bodies has passed the cart to see which measures you still need to meet. At that
standards set by the ONC and NIST. point, you can choose additional modular technology
solutions to add to your cart until you meet all required
• Certification Commission for Health Information measures as an EP.
Technology (CCHIT)
Once again, it’s important to note that if you choose to use
• Drummond Group modular technology, you’ll be responsible for managing
• InfoGard Laboratories compliance of the criteria you’re capturing for Stage 1
Meaningful Use in multiple systems – which means you’ll
• ICSA Labs also need a dashboard to help you monitor each one of your
EP’s compliance with all measures. Don’t forget that even if
• SLI Global Solutions
you don’t use all the measures in your practice, your solution
• Surescripts (handles e-prescribing, Privacy, and or solution mix must possess the capability to capture data
Security modules only) for those measures you’ve excluded.
Complete vs. Modular EHR Certification Note: Certified EHR technology requirements change
beginning in 2014, consult with your technology solutions
As discussed earlier in this guide, there are 25 certification provider regarding program-related changes. [Dreyer,
criteria that must be met (plus the 44 CQMs) to provide Jonathon L. and Keith J. Dreyer, The Radiologist's Essentials
eligible providers with a complete EHR system. In addition to to Meaningful Use: Essentials for Your First 2 Years.
the 25 certification criteria for eligible professionals, there Michigan: RMU Press, 2012. Print.]
are also eight additional criteria which vendors of certified
16
Chapter 6: Radiologists and Financial Impact to Your Organization

While the incentive opportunities are quite attractive, keep
Meaningful Use one very important factor in mind: the money that has been
Eligibility set aside to encourage an EP’s participation is just that – an
incentive. It’s not nearly enough money – nor was it
While there is an incentive program for Medicaid Meaningful intended to be used – to pay outright for your new EHR
Use, most radiologists will choose to participate in the system, especially if your organization needs to make IT
Medicare Meaningful Use Program. Keep in mind that you investments to comply with the program.
may qualify for both programs but you can only participate
in one. Also important to note: if you choose one but later However, not complying with the program will most likely
decide to participate in the other program, you are allowed force your organization to pay penalties starting in 2015,
to switch between the Medicare and Medicaid program, but which could have a significant effect on your organization’s
you can only do this one time. long-term operations and profitability.
One of the first things you must do to begin receiving Stage It’s important to review your overall cost of complying vs.
1 Meaningful Use incentive dollars is to determine whether not complying with this program early on so that you fully
you’re eligible to participate in the EHR incentive program understand the financial impact on your practice.
and which one you will participate in. The good news is,
most practicing radiologists probably are eligible, providing Before you participate, you may want to use the helpful
you are not hospital-based. “practice analyzer” at RadiologyMU.org to sign up and
access this tool. In addition, we recommend that you review
It’s actually quite simple to determine your eligibility. Check your costs over a five-year period to understand the full
the following criteria, in which you must: financial investment.
• Treat greater than 90% of your patient volume as When you review your incentive payment vs. program costs,
outpatient (POS code 22)—over 90% of your you should consider the following items in your calculations:
practice must be outpatient
• Have a National Provider Identifier (NPI) • Overall incentive payment for all EPs in your practice
(assuming you are rolling everyone’s incentive
• Register with the EHR Incentive Program - payment collectively into your practice)
https://www.cms.gov/EHRIncentivePrograms/
• Software licensing expense for existing certified
• Have a National Plan and Provider Enumeration software
System (NPPES) user ID and password
• Software licensing expense for new certified
• Be enrolled in the Provider Enrollment, Chain, and software
Ownership System (PECOS)
• Yearly maintenance charges for all software
• Provide 50% of your patient encounters at practices
or locations using certified EHR technology during • Training costs
the reporting period (one or multiple locations is • Consulting costs
acceptable but will be a challenge for an EP to track,
as it’s up to the provider to maintain records that • Estimated noncompliance penalties starting in year
show you’re in compliance with this threshold, and 2015
you can be audited for up to seven years)
Incentive Payments and Medicare Thresholds
• Fulfill the consecutive reporting requirements (90
Your overall incentive payment will be based on your yearly
days for your first year; 365 days for each
Medicare billings. The amount paid directly to each EP is
subsequent year after year one of your initial
based on 75% of his or her total allowable Medicare charges
participation)
as physician fees. (This is based on professional fees only –
technical charges are ineligible and these fees must be
submitted within two months of the calendar year-end).
17
Below is a sample chart that shows how the maximum
incentive payment is achieved based on the threshold you
Chapter 7: Developing Your
must meet in Medicare physician fee billings per calendar Strategy
year. As a reminder, in your first year, you only have to
report on 90 days of consecutive use of your EHR Where to Begin?
technology, but you will use your full year Medicare The very first thing you should do before starting on this
physician billing to determine your maximum payout: initiative is to learn as much as possible about the EHR
Incentive Program – its overall fundamentals and purpose.
Calendar Year Incentive Medicare
Begin by reviewing non-biased sites such as the ACR,
Payment Threshold RadiologyMU.org, www.CMS.gov, and theMUguide.com.
There are also numerous blogs, meetings and workshops
available to help you understand this program. The more you
2011/2012* $18,000 $24,000 understand, the better you’ll be prepared to implement
certified EHR technology and make it through a successful
2013 $12,000 $16,000 attestation so that you can receive your incentive payments.
2014 $8,000 $10,667 After you arm yourself with some basics of the program,
you’ll want to designate a champion who is a senior member
2015 $4,000 $5,334 within your organization. Make sure this person can be
available to support and explain “why” you are complying
2016 $2,000 $2,667 with this program. In addition, you’ll want to designate
someone on your staff who has researched Meaningful Use
*Only one $18,000 payment is possible, based on start year fairly extensively and can act as an expert at your facility to
of 2011 or 2012. funnel questions, comments and concerns from other staff
members, patients and referring physicians.
If your Medicare physician-fee charges exceed $24,000 in
year one, you will only be eligible for the $18,000 maximum Once you have your champion and expert, verify your
incentive payment. If you fall below $24,000 in year one, organization’s eligibility to participate (see the section in
you would be eligible for a maximum payout of 75% of your Chapter 6 on determining your eligibility).
total charges, and so on for each subsequent year, based on
each year’s Medicare threshold and corresponding maximum After you’ve determined that your organization is eligible,
incentive payment. you’ll need to understand the measures, including the
Clinical Quality Measures, and how they’ll apply to your
More about Incentive Payments practice:
Incentive payments are typically made four to eight weeks
• Select the measures you’ll track and attest to, and
(more likely count on the eight-week timeframe) after your
also select which Clinical Quality Measures you’ll
successful attestation (more on attestation later in this
report against.
guide).
• You’ll also need to note which measures apply as
The incentive payments are made to the individual eligible exclusions for your practice, as you’ll have to report
professionals or their assigned designees and will be made in these when you attest.
the same form that you receive your Medicare claim
payments. Each EP qualified to receive an incentive payment • Once you’ve determined what measures you’ll track,
will receive a separate payment, even if you‘ve opted to evaluate your current technology.
group those payments together and apply them to your • Talk to your vendors about their plans and roadmap
overall organization. Each incentive payment is made as a for complying with Meaningful Use.
single sum payment, and because it’s treated as income, is
subject to any tax implications you may have. Please consult • If you find you can’t meet your objectives with your
your tax professional for advice about your specific questions current technology, you’ll need to select new
and concerns. certified technology, which you can either use to
18
replace your existing technology (most likely a Unless you can validate all the data in a single certified
complete certified EHR for Stage 1) or complement system, you will need to have a dashboard that can track
your certified technology (most likely a modular your measures in all the certified systems you use, or one
certified EHR for Stage 1) . that can aggregate the data and generate the reports you
need to run for your attestation.
• Use the CMS website
http://oncchpl.force.com/ehrcert to get a better idea
After reviewing and redesigning your workflow, register with
of where you stand with your current technology
CMS (unless you did this earlier in the process). Each EP must
and where you’ll need to be in order to comply with
be registered because each EP will receive the incentive
the incentive program rules and criteria.
payments if they qualify for the payment in each reporting
Next, meet with your practice stakeholders and explain why period. You also have an option to have a designee within
you’re participating in this program. Again, use your your facility act on behalf of all your EPs to register and
champion to help everyone understand this is the right thing attest for each EP. If your funds will be going into your
to do and will ultimately allow you to provide better patient practice, as a suggestion, you may want to have a legal
care. document drawn up for your EPs to sign so that they’re all
aware their incentive payments are going back into your
Develop a team to help you implement, track, train and organization.
maintain compliance with your Meaningful Use Program
over time. This can be one or two individuals or a team, Following registration and during your reporting period (90
based on your facility mix, infrastructure and overall consecutive days in the first year you start the program and
workload. We suggest that you have a project manager (to full-year reporting for each subsequent year), you should
assure your site is complying with your target), security regularly monitor your progress and share with your EPs their
specialist (to assure your compliance with security and progress to date. If you are falling short in specific areas,
privacy), a support specialist (to help answer questions as you’ll have time to make adjustments so that you can meet
you move through this process), and a reporting and the requirements of the measures you’re tracking. Good
compliance specialist (to perform the attestations and assure monitoring of your progress is the key to meeting the
each EP is meeting their required thresholds for compliance). Meaningful Use objectives and ensuring your incentive
Again, this can be one or as many people as you feel you payments are approved and paid at the maximum amount
need, but it’s important to understand the requirements you allowed by the CMS. One important note on monitoring
will be taking on to comply with this program. your measures: if any of your EP’s fails at even one measure
during your attestation, you must begin the 90-day tracking
As part of your team-building, remember to meet with your process again. If you’re starting your program in 2012, start
vendors to learn about their roadmap for Meaningful Use as soon as you can prior to the October 3 final date to
and their timelines, to determine how their schedules will fit comply in 2012. That way, if you do need to make some
with your overall plans. corrections, you can restart your 90-day period and still
complete your reporting period in plenty of time to qualify
Next, it’s very important to review your overall operations for the 2012 incentive payment.
and understand how your overall workflow will change once
you implement Meaningful Use. You’ll need to determine Finally, you’ll attest that you have met the requirements of
who will enter the additional data when it comes into your the CMS Meaningful Use Incentive Program for 2012. The
office – especially if it applies to measures you’ll be tracking attestation process is your legal statement to the CMS that
and attesting to. Also, will you be capturing some of the you have fulfilled the requirements (tracked the required
data electronically from your referring physician’s certified measures using certified technology) of the program. The
EHR? Will you need to shift staff responsibilities? And the attestation process takes place on the same website and
most important thing: you’ll need to analyze and then plan system that you used to register with the CMS. During
your workflow in such a way that it doesn’t disrupt your attestation, you will need to provide some basic information
overall patient-care throughput and departmental flow. about each EP, enter answers to Core Measure questions
(including exclusions), enter answers to the Menu Set
If you’re taking a modular approach to implementing your questions (including exclusions), enter your numerators and
Meaningful Use plan, you’ll need to develop a strategy and denominators for your CQMs, and agree to the final set of
the tools to monitor your measures through a dashboard. questions to finish your attestation.
19
As a good rule of thumb, make sure the certified technology Step 5: Evaluate Your Existing Technology
you possess, or the dashboard software you’re using, has the
capability to extract the data for six years, as that is the audit You will need to evaluate your current technology to verify it
time period. In addition, keep all documentation you is 1) certified for the Meaningful Use measures you are going
generate for your attestation for six years, in case your to track and 2) that you don’t need to complement its
practice is audited. Use the steps below as a checklist when capabilities with additional certified software. Be sure to talk
developing your Meaningful Use strategy. to your IT vendors about their plans and roadmap for
complying with meaningful use, both for Stage 1 and
Suggested Steps to Achieving Meaningful Use beyond. Use the CMS website
http://oncchpl.force.com/ehrcert to help you get a better
The following “steps” have been adapted from the 10-step idea of where you stand with your current technology and
approach to meaningful use outlined in The Radiologist’s where you will need to be to comply with the incentive
Guide to Meaningful Use [Dreyer, Jonathon L. and Keith J. program rules and criteria.
Dreyer, The Radiologist's Guide to Meaningful Use.
Michigan: RMU Press, 2011. Print.] Step 6: Communicate Your Plan
Meet with your practice stakeholders and explain your

Step 1: Educate Yourself participation in this program and why you are doing it. Use
Learn as much as possible about the EHR Incentive Program your champion to help assure your staff this is the right thing
and its overall fundamentals and purpose. Use sites such as to do for your organization and to improve patient care.
the ACR.org, RadiologyMU.org, and www.CMS.gov. An
excellent set of resource books and reference guides can be Step 7: Establish Your Project and Rollout Team
found at theMUguide.com; other good sources are MU
blogs, meetings, and workshops. Develop a team to implement, track, train and maintain
compliance with your Meaningful Use Program. This can be
Step 2: Identify Your Meaningful Use Champion one or two individuals or a team, based on your facility mix,
infrastructure and overall workload. Appoint a project
Your champion should be a senior member or stakeholder manager, security specialist, a support specialist, and a
within your organization and will provide support for “why” reporting and compliance specialist.
you are complying with this program. He or she can also
provide organization strategy to your employees, patients, Step 8: Review and Change Workflow as Needed
and referring physicians. This person will be your expert to
funnel questions, comments, and concerns as they arise. Review your facility operations to understand how your
workflow will change once you implement Meaningful Use.
Step 3: Determine Your Eligibility Determine who will enter additional data when it comes into
your office; front office staff? Techs? Film/medical records
Verify your eligibility to participate (see the section in personnel? Establish interfaces with referring EMRs if you
Chapter 6 on determining your eligibility). will capture some data electronically. Finally, analyze and
plan your workflow so that it does not disrupt your overall
Step 4: Understand the Measures and CQMs patient throughput and departmental flow.
You need to understand the required measures and Clinical Step 9: Monitor Your Program
Quality Measures and how they will apply to your practice.
You will need to select those measures you will track and Monitor your measures via daily reports or via a dashboard.
attest to as well as select which CQMs you will report You will need to monitor each EP on a frequent basis and
against. You will also need to note any measures you can identify deficiencies they may have in one or more of their
exclude, as you’ll have to report these when you attest. measures. Troubleshoot and develop a plan to increase their
compliance so they meet the numerator thresholds they
need to satisfy for their given measures.
20
Step 10: Register with CMS
Chapter 8: Workflow Changes and
Register with CMS (unless you did this earlier in the process). Considerations
Each EP needs to register, as each EP will receive incentive
payments if he or she qualifies for payment in each reporting Review and Document Your Current Workflow
period. You have an option to have a designee within your Putting together and starting a Meaningful Use Program in
facility act on behalf of all your EPs to register and attest for most outpatient radiology facilities can seem like a daunting
each EP. task. However, understanding the program, including the
required data to capture, and providing solid communication
Step 11: Attestation about how the program works – and how it will benefit
patient care – will help ease your transition.
Log onto the CMS site and attest that you have met
meaningful use requirements for the year you are One of the areas that will definitely be affected is your
participating in the program. The attestation process is your workflow. Your new program will require your site to
legal statement to the CMS that you have fulfilled the capture and track a lot more data. For instance, you’ll now
requirements (tracked the required measures using certified need to track patient medications and any allergic reactions
technology) of the program. During attestation, you will 1) your patients may have had.
provide some basic EP information; 2) enter answers to Core
Measure Questions (including exclusions); 3) enter answers The best place to start is to fully understand what your
to the Menu Set Questions (including exclusions); 4) enter current workflow is. In other words, document and
your numerators and denominators for your CQMs; and 5) flowchart what each of your staff members does each week
agree to the final set of questions and provide your and look at how much time they spend today capturing and
attestation. Be sure to retain all documentation that supports entering patient data into your IT systems. It’s a good idea to
your attestation for six years, in case you are audited. review all steps, methods, processes and/or tasks that each
individual performs in your organization.
Once you understand your current processes, consider how

each staff member’s job and processes will change once you
get going with your Meaningful Use measures. Remember, it
will be up to your staff to enter the data required for the
measures you’re tracking for each EP throughout your
reporting period. Explaining the reasons for the changes and
working with your staff to assure that you’ll keep the
additional data entry to a minimum will go a long way to
keeping you on track with your Meaningful Use goals.
“Seen by the EP”

There may be some confusion about who exactly needs to
enter the data the EP will be attesting to. After all, if only
radiologists could enter the data required for each study, it
would cripple workflow, add undue costs and probably
ensure failure with the overall program.
The good news is, the CMS has clarified what it means to
“be seen by the EP” for the specialty-practice settings that
fall outside the typical “patient/physician” relationship most
general practitioners follow. Below are excerpts from the
CMS FAQ library to clarify what “seen by the EP” means.
21
FAQ#10664, published 06/062011
Question: For the Medicare and Medicaid EHR Incentive Programs, how does an eligible professional (EP)
determine whether a patient has been "seen by the EP" in cases where the service rendered does not result
in an actual interaction between the patient and the EP, but minimal consultative services such as just
reading an EKG? Is a patient seen via telemedicine included in the denominator for measures that include
patients "seen by the EP"?
Answer: All cases where the EP and the patient have an actual physical encounter with the patient in which they
render any service to the patient should be included in the denominator as seen by the EP. Also a patient seen through
telemedicine would still count as a patient "seen by the EP." However, in cases where the EP and the patient do not
have an actual physical or telemedicine encounter, but the EP renders a minimal consultative service for the patient
(like reading an EKG), the EP may choose whether to include the patient in the denominator as "seen by the EP"
provided the choice is consistent for the entire EHR reporting period and for all relevant meaningful use measures. For
example, a cardiologist may choose to exclude patients for whom they provide a one-time reading of an EKG sent to
them from another provider, but include more involved consultative services as long as the policy is consistent for the
entire EHR reporting period and for all meaningful use measures that include patients "seen by the EP." EPs who
never have a physical or telemedicine interaction with patients must adopt a policy that classifies as least some of the
services they render for patients as "seen by the EP" and this policy must be consistent for the entire EHR reporting
period and across meaningful use measures that involve patients "seen by the EP" -- otherwise, these EPs would not
be able to satisfy meaningful use, as they would have denominators of zero for some measures.
FAQ#10665, published 06/06/2011
Question: For the Medicare and Medicaid EHR Incentive Programs, when a patient is only seen by a member of
the eligible professional's (EP's) clinical staff during the EHR reporting period and not by the EP themselves, do
those patients count in the EP's denominator?
Answer: The EP can include or not include those patients in their denominator at their discretion, as long as the decision
applies universally to all patients for the entire EHR reporting period and the EP is consistent across meaningful use
measures. In cases where a member of the EP's clinical staff is eligible for the Medicaid EHR incentive in their own right (NPs
and certain physician assistants (PA)), patients seen by NPs or PAs under the EP's supervision can be counted by both the NP
or PA and the supervising EP as long as the policy is consistent for the entire EHR reporting period.
For more information about the Medicare and Medicaid EHR Incentive Program, please visit
http://www.cms.gov/EHRIncentivePrograms
Areas Where Workflow May Change Workflow Considerations

In summary, as long as you apply your methods consistently Each of your EP’s staff will, in virtually all instances, be
vs. creating “one-offs,” the CMS fully accepts the fact that responsible for documenting in certified technology the
being “seen by the EP” can also translate to the EP’s clinical information needed to comply with measures for Meaningful
staff. In other words, being “seen by” the EP can extend to Use. Data captured on paper cannot be included in your
your radiology clinical staff and those exams can be counted calculations unless that data is entered into your certified
in your calculations. The EPs can choose which exams to technology as part of your tracking for that measure. When
count or exclude in their calculations, based on this guidance you’re attesting, keep in mind that you’re required to
above. provide all numerator and denominator information directly
from your certified technology. It’s also permissible to
22
include data from an uncertified system, as long as the data exam, so this could also be considered as part of your efforts
is correctly entered into the certified technology and used in to provide better patient care.
your final calculations.
Registrations
Because every radiology practice is different, there’s no
single, correct workflow that can be applied to every facility A. If your front office is not too crowded and
– which is why you need to document and understand your registrations don’t typically back up, you may want
current workflow. You may choose to capture much of the to consider having your registration staff collect
data during scheduling, or maybe scheduling is so fast-paced additional Meaningful Use information about
and busy at your site that you create a callback/reminder patients when they arrive at your facility. Items to
program to capture the data. As another alternative, you ask would include verification of demographics,
could capture the data at the time of registration and either immunization history, allergies, tobacco use,
enter it then or after each patient leaves. medication lists, and e-mail addresses so that you
can send copies of their records, as required.
But even though each facility is unique, these are some
general considerations to think about as you plan how you B. If your front office is very hectic and it’s a burden for
will capture your meaningful data into your certified staff to enter additional data (sometimes the
technology. Some of the following suggestions have been medication, allergy, and immunization lists can get
used by outpatient radiology practices that have successfully rather lengthy for data entry), consider having your
attested to, and received, their incentive checks for staff gather the data suggested in section “A”
complying with Meaningful Use. above but then move the data entry to your
film/medical records staff to input. Offloading the
Scheduling information documentation to another department
(whose role is most likely changing anyway, with the
A. If your scheduling department can spend some advent of digital imaging), provides a faster
additional time on the phone with the referring registration process while you also enter the data
physician office or patient, select which data into your certified technology against your
elements your staff will ask for during scheduling. Meaningful Use measures.
You may wish to consider having them capture
height, weight, immunizations, tobacco use, Here are some additional suggestions to consider as you
allergies, medications and ethnicity. change processes for your front office staff or film/medical
records staff:
B. If your scheduling department cannot spare
additional time on the phone, consider having them 1. Record the date when patients request an electronic
ask for one or two additional pieces of information, copy of their health information, in addition to the
such as height and weight, or tobacco use and fulfillment date.
ethnicity.
2. Provide patients with specific education materials or
Obviously, the data you receive is only as good as what the resources.
physician’s office or patient is willing to provide you at the
time you’re scheduling each exam. 3. Implement decision-support rules based on patient
exams (the MRI rule if a patient has a pacemaker;
Appointment Reminders MRI rule if history of metal in eyes requires orbital
X-rays; diabetic rule for CT contrast exams;
If your facility has never implemented a schedule-reminder screening mammo exams one year out for patients
program, you may want to consider it now. If your over “X” years old, etc.). The rules you choose to
scheduling department is so busy that they cannot afford implement will be based on the capabilities of your
extra time to collect additional data, you may want to certified technology.
contact patients in the evening a few days prior to their
exam to collect the additional data suggested above. Your
patients may also have additional questions about their
23
Technologists Final Considerations
Your technologists will most likely capture additional data, There are a few other measures that may require you to
such as patient vitals and blood pressure. This is typically adjust your workflow and consider who will enter that
done for some special-procedure exams but is not a typical information, and when:
task prior to taking general X-rays. This will obviously place
another burden on your technologists unless they can get • Medication reconciliations
the vital signs from referring physicians or directly from
patients. • Patient summary records (for transition of care)
• Clinical summary records
In addition, if you track lab values, the technologists may be
responsible to enter that information into your certified The above items are episodic, so you’ll want to enter these
technology. Again, the tech or tech aid can enter this for each patient encounter.
information or you could have your film/medical records staff
do so after patients have left. What’s very important is to Keep in mind that the overall effects on your workflow will
make sure that whatever process you choose, you also add be based on which measures you choose to track and report
the information to your patients’ records. Obviously, if you against. After you’ve reviewed your workflow, it’s a good
can send some lab data electronically to your certified idea to provide several training sessions to make sure your
technology, it will greatly decrease the burden on your staff. staff is comfortable with the new changes. Also, we highly
recommend that you start your 90-day reporting period (or
Physicians run a trial) ASAP to get your staff used to the changes in
their daily routines. If you need to make adjustments that
Ideally, you want to keep additional data entry to a require you to restart your reporting period, a trial run will
minimum for your radiologists to avoid a bottleneck in their give you that extra time. The key is to continually monitor
overall workflow. There are two areas where they may need the workflow early in the process and make the necessary
to take action to comply with Meaningful Use in your adjustments so that you can minimize the extra data-
certified technology: capture burden on your staff.
• eRx – radiologists must use certified electronic

technology.
• Review allergy and medication alerts – radiologists
must review any contraindication alerts.
Both of these should be part of your certified technology.
However, if your radiologists write fewer than 100
prescriptions each year, they may choose to be excluded
from the eRx measure. Note that while your technology
must still possess that capability, you may choose to
designate it as one of your exclusions.
24
your Meaningful Use objectives and compliance using
Chapter 9: Meaningful Use and certified technology.
Vue RIS
In fact, the CARESTREAM Vue RIS has a unique certification
How Vue RIS Helps You with Meaningful Use through the ONC-ATCB. Vue RIS is currently certified as a
If you’re reading this chapter, you’ve probably purchased the complete EHR for eligible professionals (EPs) with modular
CARESTREAM Vue RIS or are considering purchasing it in the certification for eligible hospitals (EHs). This dual certification
future, and are curious about how it will help you achieve can allow Vue RIS to operate in some unique situations.
Source: oncchpl.force.com/ehrcert/EHRProductSearch
Vue RIS has obtained complete EHR certification for Stage 1 The rest of this chapter will walk you through the various
Meaningful Use and Carestream is totally committed to areas where you’ll input – manually or electronically (via an
keeping our technology up to date with the various stages of HL7 interface) – the Meaningful Use data your site chooses
Meaningful Use. We’re currently in the process of planning to capture for each of your EPs.
our Stage 2 development and commercialization rollout to
meet the 2014 requirements.
25
Vue RIS and Measure Certification received certification. You can also visit:
http://oncchpl.force.com/ehrcert
Searching for Carestream on the ONC’s website will provide
you with the measures and CQMs for which we’ve already
Source: oncchpl.force.com/ehrcert
26
Source: oncchpl.force.com/ehrcert/
27
Source: oncchpl.force.com/ehrcert/certificationcart
Vue RIS and Data Capture While we recognize that many referring physician offices
may choose to not use the Vue RIS to enter data, interfaces
This section features the data fields available to your site for can be developed between their EMR systems and our RIS,
capturing data in the Vue RIS. If you’re a current Carestream which will allow for electronic capture of the required data
customer and are using or are planning to use the Vue RIS, for Meaningful Use.
you’ll want to refer to your product documentation for any
questions related to data entry, layout and reporting that Finally, as will be the case for most sites early on, most of
aren’t covered here. You can also talk with your applications your meaningful data will need to be captured manually by
specialist for additional information. your staff. The Vue RIS screens have been designed to be
similar and consistent across all user profiles with access to
Patient Demographic Data the core patient demographic data. Your security privileges
may or may not allow you to enter and/or change patient
Vue RIS has the capability to allow your referring physicians demographic data. The figure below shows the patient
to electronically submit order requests for radiology exams to demographic data fields you’ll enter:
your facility. Providing referring physicians with the screens
to enter meaningful data can save your staff a lot of time
when it comes to data entry.
28
Lab Data and Vital Signs

The data captured in the figure above satisfies the following
Meaningful Use measures: As you become familiar with the layout of Vue RIS, you’ll
notice that data is logically grouped together in tabs to help
Ambulatory Criteria 170.304 you find specific data categories. There are two “Clinical
History” tabs in Vue RIS. The first is where you’ll capture
42 CFR §495.6(d)(7) – Record demographics: preferred patient lab data and vital signs, and the second is where you
language, gender, race, ethnicity, date of birth (required for record vital signs, as shown in the figure below:
50% of all unique patients over the age of 2 in order to
comply with this measure).
General Criteria 170.302
42 CFR §495.6(d)(9) – Record smoking status for patients

ages 13 and older (required for 50% of all unique patients
over 13 years old to comply with this measure).
Although we’re not discussing hospital-specific criteria in

this guide, note that Vue RIS will prompt users for an
advance directive if a patient is over the age of 65, as
shown in this next figure:
29
Notice that in both instances, lab data as well as growth as structured data for more than 50 % of all unique patients
charts can be displayed graphically as new data is entered, ages 2 and older that are seen by the EP.)
which allows you to view data across time.
Vaccines, All Conditions, Medications, and Allergies
The data captured in the figure above satisfies the following
Meaningful Use measures: The second clinical history tab (“Clinical History 2”) is where
you’ll enter patients’ vaccines, all patient conditions, all
General Criteria 170.302 medications and all allergies as displayed in the figure below:
42 CFR §495.6(e)(2) – Incorporate clinical lab test results into

certified EHR technology as structured data (more than 40%
of all clinical lab tests results ordered by the EP during the
EHR reporting period whose results are either in a
positive/negative or numerical format are incorporated in
certified EHR technology as structured data).
42 CFR §495.6(d)(8) – Record and chart changes in vital

signs: height, weight, blood pressure. Calculate and display
BMI, plot and display growth charts for children ages 2-20
(including BMI). (Record height, weight, and blood pressure
30
The data captured in the figure above satisfies the following Decision-Support Rule
Meaningful Use measures:
As you’ll recall, you may select or create one decision-
General Criteria 170.302 support rule to implement at each EP’s discretion, based on
your scope of practice. While there are many rules you can
42 CFR §495.6(d)(3) – Maintain an up-to-date problem list of use within radiology, the following is an example of a
current and active diagnoses (record at least one entry or an decision-support rule that is launched when the user orders
indication as structured data that no problems are known for an MRI exam on a patient with a pacemaker:
more than 80% of all unique patients seen by the EP).
42 CFR §495.6(d)(5) – Maintain an active medication list

(record at least one entry or an indication as structured data
that more than 80% of all unique patients seen by the EP
are not currently prescribed any medication).
42 CFR §495.6(d)(6) – Maintain an active medication-allergy

list (record at least one entry or an indication as structured
data that more than 80% of all unique patients seen by the
EP have no known medication allergies).
31
The rule in the figure above would satisfy measure: Vue RIS incorporates several decision-support rules that are
standard and were used as part of our ONC certification
Ambulatory Criteria 170.304 with CCHIT. A limited number of additional rules can be
created as part of your implementation (based on your
42 CFR §495.6(d)(11) – Implement one clinical decision- current statement of work). They can also be purchased and
support rule relevant to your specialty or high clinical priority implemented, based on your site needs. The following figure
along with the ability to track compliance with that rule shows a list of the rules that come standard with Vue RIS:
(implement one clinical decision-support rule).
32
Additional Measures Other Measures
Vue RIS has been certified for a total of nine CQMs. You can also use Vue RIS to submit syndromic information to
However, the rest of the measures are difficult to show with other certified systems, when needed. And after your first
screen captures. These include privacy and security year of attestation, Vue RIS has the capability to send your
measures, access to electronic information, CQMs (three numerator, denominator and CQM information directly to
core plus three alternate), public surveillance, immunization- the CMS to help you meet your annual attestation
submission capabilities, automated measurements, data- requirements.
exchange encryption and patient-list generation.
Finally, you can share access to patient results and education
e-Prescribing, Drug-Drug, and Drug-Allergy materials with patients – all from within Vue RIS. This means
it’s the only solution you need in order to comply and sustain
Vue RIS has embedded the DrFirst application into our RIS to Meaningful Use measures at your outpatient imaging facility.
satisfy the requirements for e-Prescribing, drug-drug and
drug-allergy interaction checks. DrFirst partners with more
than 200+ healthcare IT vendors and is a very mature, ONC-
certified product that works quite easily with other third-
party EHR and RIS solutions.
You can find out more about the capabilities of this

application via the DrFirst website: www.drfirst.com.
33
must have the data keyed into your certified technology and
Chapter 10: Attestation the data you enter must meet the reporting-period time
Attestation requirements (90 days of consecutive use in year one and
365 days for each subsequent year).
After you’ve followed all the steps we’ve outlined here –
decided to participate in the CMS incentive program for You’ll use your certified technology to enter the requested
Meaningful Use, analyzed your organization’s certified data during the attestation process. Once you enter the
technology and workflow, trained your staff, implemented required data, the system will show you a summary of your
your solution, and captured your data – you’re ready to results and accept or reject your results. If your data are
attest to the CMS that you’ve fulfilled the requirements to rejected, contact your Regional Extension Center for
meet Stage 1 Meaningful Use. This section explains a bit guidance.
about that process and what you can expect.
Attestation Steps
Before You Begin
The following screens will briefly walk you through the steps
Remember that before you attest to anything, the data you required to attest. For more information, please review the
will be attesting to must come from certified technology, not attestation process and use the online tutorials, etc. at the
paper records. However, if you do have some paper records, CMS website: http://www.cms.gov/Regulations-and-
you may enter that information into your certified Guidance/Legislation/EHRIncentivePrograms/EducationalMate
technology to fulfill some requirements (such as patients rials.html
supplying you with their medication lists). Either way, you
34
Step 1: Log on to the Registration and Attestation System
The CMS has created a special website for the EHR incentive program registration and attestation. The web address is:
https://ehrincentives.cms.gov/hitech/login.action
Step 2: Assemble the data from your certified technology
You’ll need your numerator and denominator information from your certified technology to complete this process for each EP you
are attesting for. Make sure you have all that ready and available to help speed you through the attestation process.
Step 3: Enter your basic information
You’ll need to enter the following information to begin the attestation process:
• EHR certification number (note that this is different than the number the ONC issues to the EHR vendor)
• Reporting-period start date
• Reporting-period end date
35
Source: CMS Attestation User Guide for Eligible Professionals (01.01.12 Ver3)
36
Step 4: Enter your Meaningful Use Core Measures
The next section includes 15 questions related to your Meaningful Use Core Measures. Be sure to indicate if you have exemptions
to any of the Core measures. Important: for question number 10, you must specify that you’re reporting your CQMs in the
manner the CMS has requested – if you answer “no” to question 10, you won’t receive your incentive payment.
37
Step 5: Enter your Meaningful Use Menu Measures
The next section covers the comprehensive list of 10 Meaningful Use Menu Set items. Select the five you will report against, and
be sure to indicate if you have any exclusions for those you have chosen not to report. Remember – you must include one public-
health measure plus four others, even if you have an exclusion. The next three figures show the 10 items from the Men Set list,
one of the public health questions, and one of the Menu-Set questions:
38
39
Step 6: Enter your CQM data
The next section instructs you to input data from your three Core or Alternate Core CQMs. After entering this data, you’ll also
need to select three additional CQMs for which you’ll enter numerator and denominator information.
You have the option to submit this information electronically; however, using this guide and during your first reporting year using
Vue RIS, you’ll most likely want to enter your CQMs manually. The next few figures show what you can expect to see during this
part of the attestation process:
40
41
42
43
44
Step 7: Confirm your attestation
After successfully entering all your information in the attestation system, you’ll review what you’ve entered, verify your status is
complete for all areas, submit your attestation, and receive a confirmation or rejection of your attestation. The figures below are a
subset of the screens you’ll see as you complete these final steps in the attestation process:
45
46
47
Step 8: Receive your incentive payment
Following submission of your attestation, you can expect to receive your check in four to eight weeks (closer to eight weeks is
more likely). After this point, please remember to keep all supporting data you used for your attestation for at least six years in
case you are audited.
For complete information about the attestation process, what to do if your claim is rejected, and up-to-date comprehensive
tutorials on the attestation process, please download the CMS Attestation User Guide for Eligible Professionals at the following
site: http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/downloads//EP_Attestation_User_Guide.pdf
Note that there’s a separate guide for Eligible Hospitals during their attestation process.
48
would need to achieve Stage 1 Meaningful Use in
Chapter 11: What's Next? 2013 to avoid a payment adjustment in 2015.
Looking Forward to Stage 2 • Providers may need to continue to demonstrate
In February 2012, the CMS released the Stage 2 Notice of increasingly complex stages of Meaningful Use to
Proposed Rule Making (NPRM) and in March, the ONC avoid penalties.
released the standards for Stage 2 certification, which were • Imaging has been added as one of the menu
published in the Federal Register. objectives for more than 40% of all exams.
Stage 2 criteria and proposed changes were reviewed for a • The “must possess” capability has been removed
specified public period, which ended May 7, 2012. The CMS from measures where you claim exclusions;
released the final rules for Stage 2 in August 2012. One of however, any site implementing Meaningful Use
the bright spots that the CMS has added is a menu set measures prior to 2014 will still need to purchase
measure (with exclusion) to include imaging in certified software that covers their exclusions.
EHRs, as well as additional radiology specific CQMs were
incorporated as well. The key to these new measures is the • The CMS is setting up some hardship exemption
cooperation that the CMS and ONC are trying to achieve levels to allow physicians more time to participate in
with specialty practices. The Meaningful Use program will Meaningful Use in order to delay penalties that
still be a one-size-fits-all program but the additional begin in 2015.
measures in future stages will begin to address the specialty • There will be 15-16 CQMs that apply to radiology,
practices. but again, this may change, based on the final
ruling.
Stage 2 High-Level Overview
• Ten percent (10%) of patients must download or
The following details, at a high level, are the changes that view their medical information.
have been proposed as the country moves toward Stage 2
Meaningful Use (Keen, Cynthia E. “Deadline Looms for • Radiology orders will be considered as part of the
Comment on Stage 2 MU Proposals,” AuntMinnie.com, computerized provider order entry (CPOE)
13 Apr. 2012. Web. 20 Apr. 2012. requirement.
<http://www.auntminnie.com/index.aspx?sec+sup>): • Menu Set Measures that promote cancer registry
and specialty society registration and participation
• Extend the time by one year for EPs who in 2011 will be added.
attested they were meeting Stage 1 final rule
requirements. CMS is proposing that each EP spend In Summary
two years in each stage but is also recommending We hope this guide has provided you with some clear, easy-
that those who attested in 2011 would remain in to-understand information about the road to Meaningful
that category until 2014. Use. The program’s sole intent is to foster better exchange
of patient information between caregivers, which will
• Stage 1 requirements will be updated so that they
ultimately lower healthcare costs through the use of
are more consistent with the plan’s overall strategic
technology.
direction. Most, but not all, of the proposed Stage 1
revisions can be adopted in 2013 and will be
Stage 1 “sets the table” for capturing patient data, clarifies
required in 2014.
which data is important to capture and specifies how to
• The complexity of Stage 2 measures is greater than store it. Stage 2 will explore how to use that data in a
those of Stage 1; many have multiple parts. meaningful way. And Stage 3 will focus primarily on decision
support and better outcomes.
• It will not be necessary to use a Health Information
Exchange (HIE) to exchange information. However, We understand that the Meaningful Use journey can at
sharing of health data will force real-time, high- times be confusing, but experts predict it will also serve as
quality data capture, from other providers and from one of the greatest advances to the U.S. healthcare system.
patients. Patients will begin to participate during Continue to read and stay informed about the Meaningful
Stage 2. Use Program as it grows – because it will certainly impact
• A change in the payment-adjustment policy would your organization, now and in the future.
mean that providers who attested in 2011 or 2012
49
Appendix 1: Resources
Overview of the CMS EHR Incentive Programs: https://www.cms.gov/Regulations-and-
Guidance/Legislation/EHRIncentivePrograms/index.html?redir
ect=/EHRIncentivePrograms/01_Overview.asp
ONC Certified Health IT Product List: http://oncchpl.force.com/ehrcert
RadiologyMU.org: http://radiologyMU.org
Meaningful Use Books and CMS EHR Incentive Program http://theMUguide.com

Reference Guides:
Radiology and HIT Blog: http://radiologyandhealthit.com
Meaningful Use Monitor Requirements Community: http://www.everythinghitech.com/mum_requirements
HITECHAnswers: http://www.hitechanswers.net
HIMSS.org: http://himss.org/ASP/index.asp
Appendix 2: Works Cited

Dreyer, Jonathon L., and Keith J. Dreyer. The Radiologist's Guide to Meaningful Use: A step-by-step approach to the Stage 1 CMS
EHR Incentive Programs. First ed. Highland: RMU, 2011. Print.
Dreyer, Jonathon L., and Keith J. Dreyer. The Radiologist's Essentials to Meaningful Use: Essentials for Your First 2 Years. First ed.
Highland: RMU, 2012. Print.
"EHR Incentive Program." CMS.gov. Web. 17 Apr. 2012. <https://www.cms.gov/Regulations-and-

Guidance/Legislation/EHRIncentivePrograms/index.html>.
Keen, Cynthia E. "Radiology, Community Home." AuntMinnie.com. AuntMinnie.com, 13 Apr. 2012. Web. 20 Apr. 2012.
<http://www.auntminnie.com//index.aspx?sec=sup>.
"RadiologyMU.org." RadiologyMU.org. RadiologyMU.org, 2010-2012. Web. 23 Apr. 2012.

<http://www.healthmu.org/radiology/index.php>.
"Using the CHPL Website." Certified Health IT Product List. ONC HIT, 2010. Web. 23 Apr. 2012.
<http://oncchpl.force.com/ehrcert>.
www.carestream.com
Carestream Health, Inc., 2012. CARESTREAM is a trademark of

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Meaningful Use | A Guide For Radiology

Chapter 1: Meaningful Use Legislation and its Impact on Healthcare.................................................................................... 4

Meaningful Use Defined.............................................................................................................................................................. 4

Electronic Patient Records ........................................................................................................................................................... 4

Goals of Meaningful Use............................................................................................................................................................. 4

Medicare and Medicaid Programs ............................................................................................................................................... 5

About Stage 1 Meaningful Use ................................................................................................................................................... 6

About Stages 2 and 3 ................................................................................................................................................................. 6

Chapter 2: Meaningful Use Legislation...................................................................................................................................... 6

A Brief History of How We Got Here ........................................................................................................................................... 6

Federal Agencies ......................................................................................................................................................................... 6

Chapter 3: Incentives and Penalties ........................................................................................................................................... 8

Incentives Available for Meaningful Use ...................................................................................................................................... 8

The Penalties for Noncompliance ................................................................................................................................................ 9

Receiving Your Incentive Payment ............................................................................................................................................... 9

Chapter 4: Meaningful Use Measures for Radiology.............................................................................................................. 10

Vue RIS and Core Set Measures ................................................................................................................................................ 12

Menu Set .................................................................................................................................................................................. 12

Vue RIS and Menu Set Measures............................................................................................................................................... 15

Clinical Quality Measures (CQMs).............................................................................................................................................. 15

Certified EHR Technology.......................................................................................................................................................... 16

Complete vs. Modular EHR Certification.................................................................................................................................... 16

Chapter 6: Radiologists and Meaningful Use .......................................................................................................................... 17

Financial Impact to Your Organization....................................................................................................................................... 17

Incentive Payments and Medicare Thresholds ............................................................................................................................ 17

More about Incentive Payments ................................................................................................................................................ 18

Chapter 7: Developing Your Strategy...................................................................................................................................... 18

Where to Begin? ....................................................................................................................................................................... 18

Suggested Steps to Achieving Meaningful Use .......................................................................................................................... 20

Chapter 8: Workflow Changes and Considerations................................................................................................................ 21

Review and Document Your Current Workflow......................................................................................................................... 21

“Seen by the EP” ...................................................................................................................................................................... 21

Areas Where Workflow May Change ........................................................................................................................................ 22

Chapter 9: Meaningful Use and Vue RIS.................................................................................................................................. 24

How Vue RIS Helps You with Meaningful Use ........................................................................................................................... 25

Vue RIS and Measure Certification ............................................................................................................................................ 26

Vue RIS and Data Capture......................................................................................................................................................... 28

Chapter 10: Attestation............................................................................................................................................................. 34

Before You Begin ...................................................................................................................................................................... 34

Looking Forward to Stage 2 ...................................................................................................................................................... 49

Stage 2 High-Level Overview ..................................................................................................................................................... 49

Appendix 1: Resources .............................................................................................................................................................. 50

Appendix 2: Works Cited .......................................................................................................................................................... 50

Timing Available in 2011 Begins in 2011, depending on state law

About Stage 1 Meaningful Use Chapter 2: Meaningful Use

Specifies criteria that eligible Sets standards, implementation

Provides ongoing guidance and Complying with the established

Calendar Year 2011 2012 2013 2014 2015+

2011 Up to $18,000 ---- ---- ---- $0

2012 Up to $12,000 Up to $18,000 ---- ---- $0

2013 Up to $8,000 Up to $12,000 Up to $15,000 ---- $0

2014 Up to $4,000 Up to $8,000 Up to $12,000 Up to $12,000 $0

2015 Up to $2,000 Up to $4,000 Up to $8,000 Up to $8,000 $0

2016 ---- Up to $2,000 Up to $4,000 Up to $4,000 $0

Total Up to $44,000 Up to $44,000 Up to $39,000 Up to $24,000 $0

Source: Centers for Medicare and Medicaid Services

Calendar Payment Reduction

Chapter 4: Meaningful Use Core Set

Objective Measure Exclusion