EHR Medicare Incentive Program Overview for Radiology

Although October 1, 2011 was the last day for Meaningful Use (MU) reporting in calendar year 2011, radiologists can still qualify for full incentive payments. However, there isn’t much time left. The last date for Eligible Professionals (EP’s) to begin using certified technology to start recording for Stage I meaningful use, is now just under a year away on October 1 of 2012.

One thing to remember is that the EHR Incentive Program has penalties as
well as incentives. The incentive is up to $44,000 per radiologist for demonstrating
compliance with the meaningful use criteria starting in 2011. Looking at a group of
20 radiologists, the total impact to the practice could be a much as $880,000. The ACR estimates that 86% of all radiologists are eligible professionals, i.e., qualifying for EHR incentive payments. If all eligible radiologists qualified, that would total $1.5 billion in payments to radiology.

The incentive is reduced in 2013 for those just starting to comply, it drops to a maximum of $39,000. and drops further to a maximum of 24,000 in 2014 for each radiologist. The penalty phase starts in 2015. Medicare reimbursement for radiologists, not demonstrating compliance, starts dropping 1% per year up to 5% of total Medicare Fees.

Most radiologists thought that they were not included in the program and indeed, in the original stimulus act, they were not. However, the Continuing Extension Act of 2010 moved hospital outpatients from the hospital base to the professional base.

Two criteria must be met to be an Eligible Professional (EP) for the Medicare Meaningful Use program. First the professional must be a physician. Second, the physician must not be “hospital-based”.

Hospital-based physicians are defined by the CMS Place of Service Code (POS). To be a hospital-based physician, requires that 90% or more of CMS covered services be performed in either POS 21 (inpatient hospital) or POS 23 (ER). Hospital outpatient settings (POS Code 22) are not considered hospital under the EHR Incentive Program.

Radiologists have been slow to get on board the program. The year to date CMS EHR Incentive Program Statistics (http://go.cms.gov/o0d8c3) show that of the specialties receiving payments, the majority are internal medicine and family practice at 22% and 20% respectively. The next most represented group are cardiologists, representing 8% of the total. Radiologists are combined into “other” category, following 7 other specialty professions that were listed separately.

The good news is that there is time for radiologists to start compiling and benefit from the program while avoiding the penalties. The bad news is that time is running short. The Meaningful Use process is designed in three stages with each subsequent phase defined after the first one starts.
Stage I: Electronic Data Capture and Sharing started in 2011
Stage II: Clinical Decision Support 2014 (proposed delay from 2013)
Stage III: Improved Outcomes 2015 (tentative)

Each phase is more challenging than the previous and requires including a higher percentage of patents be included in the EHR with the end game of a 100% EHR in the US. A solid foundation for Stage I is required to keep pace with the Stage II and III.

Radiology can still start Stage I planning. MU registration can be done in advance of the implementation. The minimum requirements for each radiologist will need to be determined as will the current capability of the IT systems, RIS, PACS, EHR, etc. and their certification status. Vendor support, hospital IT support, and the MU activity of other specialties will all factor into the specific plan and implementation.