July 2012 
Meaningful Use – Don’t Forget about Radiology
When developing an IT strategy to achieve Stage 1 of Meaningful Use, hospitals are urged to consider the implications for Radiologists. According to industry reports, most organizations are unaware of, and have not prepared to address the HIT requirements that will affect them related to providing outpatient radiology services.
Even if your organization does not employ eligible providers in ambulatory settings, Radiologists who provide more than 10% of their services (which includes invasive procedures and diagnostic services) are subject to the Stage 1 Meaningful Use requirements for eligible providers. The basis for determining outpatient volume is the sending of claims for a service using place of service code 22. This would apply to almost every hospital that has a Radiology Department.
Compliance: Incentives and Penalties
Radiologists who comply can receive $63,000 if they qualify and select the Medicaid option and $44,000 per provider for Medicare. In order to receive the maximum stimulus money, they must attest as Eligible Providers – no later than December 31, 2012.
Radiologists will also be subject to Medicare penalties if they do not comply with the MU requirements by Jan 1, 2015. This means they will need an EMR that is certified as an AMBULATORY product. They need to have it in place and start measuring by October 1 of this year in order to receive full stimulus incentives. Medicaid-eligible providers can extend the time to meet these requirements by one year if they select the Acquire, Implement, Upgrade option.
Utilizing EMR to Achieve Requirements  
“Hospitals need to evaluate and consider how the radiology services they provide will affect their Meaningful Use compliance.”
Jim Deren
Strategic IT Planning CareTech Solutions
It may be possible to utilize part of your inpatient EMR to achieve five of the requirements per the CMS hybrid provision – meaning the product addresses both inpatient and outpatient requirements. These requirements include Medication CPOE, one clinical decision support rule, recording demographics, providing an electronic copy of health information to a patient, and exchange of clinical information with other providers. EPs that choose to leverage the new hybrid flexibility still need technology certified for all non-hybrid Ambulatory criteria.
Please note that a number of requirements can be claimed as exclusions for Radiologists as they they may not apply to providing diagnostic radiology services such as;  
  • Providing clinical summaries if there is no office visit
  • Entering medication orders – if the radiologist writes less than 100 Rx orders
  • Capturing immunization data
  • E-prescribing
  • Capturing structured lab data if no lab orders are placed by the Radiologist
  • Performing med reconciliation if the Radiologist was not a recipient of a care transition
  • Providing a summary care record for transitions of care if none occurred
  • Providing patients with an electronic copy of their health information
  • Submitting electronic syndromic surveillance data
Impact on Workflow  
The impact on workflow may be significant because you may need both an inpatient product for the hospital and outpatient product or RIS attached to your EMR for the Radiologists.
Although organizations that do not employ Radiologists are not responsible to address these requirements, it is likely that your Radiology group will desire assistance in order for them to gain compliance. If you have not accommodated this requirement into your IT planning, we encourage you to check with Radiology and EMR vendor to see what capabilities currently exist.  

Additional information may be found at www.radiologyMU.org