Meaningful Use at Five

It is hard to believe that radiology has been part of the federal meaningful use (MU) program for five years. It has been a tough journey: From the onset, we have been tracking measures that are not typically related to radiology workflows, implementing system requirements not particularly used in medical imaging settings and adding complexity and costs in areas that do not necessarily add value to our radiology operations or to our patients.

Similar to other overarching healthcare programs, MU has shown us that one size definitely does not fit all. The eligible professional (EP) component of the program was developed with primary care, family doctors and pediatric facilities in mind. Radiology was, at best, an afterthought.

Over the years, however, simplifications have been introduced and exclusions created in order to ease implementation and improve adoption across the medical specialties. That said, the whole concept still remains foreign to day-to-day radiology operations. Most adoption in radiology has been fostered by financial incentives, compliance and, or, cost avoidance—far removed from the original, altruistic program goals to lower healthcare costs, cut medical errors, improve patient care and, ultimately, improve patient outcomes.

That said, not all is lost. There are systemic gains promoted by MU that can, in fact, directly benefit radiology operations and radiologists. For instance, universal adoption of e-prescription; electronic filing of laboratory results; increased EP interest in establishing electronic orders/results interface with radiology; improved access to resources to educate patients about their conditions and treatment options; improved access to EHR data in general, including remote access to the patient’s chart; proliferation of results portals now enhanced with the patient’s ability to view, download or transfer their own records; and improved IT security awareness. These all are examples of MU measures that brought tangible benefits to the healthcare environment. In addition, clinical decision support (in particular when applied to the appropriateness of the imaging exam order) and health information exchanges hold tremendous opportunities for radiology leadership and steerage.

A zero-sum program

Still unconvinced of the benefits of MU? I can’t blame you; in fact, your skepticism is shared among other EPs, some of whom are out of the program altogether despite successful initial participation. Having said that, MU is not winding down following the MU stage 3 performance period proposed to start in 2017. Quite the opposite is indicated.

The so-called “doc fix” bill passed in April of this year established a new pay-for-performance program affecting Medicare reimbursement starting in 2019: the Merit-Based Incentive Payment System, or MIPS. With MIPS, the MU program, the Physician Quality Reporting System (PQRS) and the Value-Based Modifier (VBM) programs are consolidated to create a single measure of physician performance—the MIPS score—that, in turn, will determine the EP’s Medicare reimbursement in each payment year. The new incentives range from ±4% in 2019 to ±9% in 2022 and beyond. Conceived as a zero-sum program, MIPS incentives paid to the higher performers will be derived from penalties applied to the laggards.

The MIPS score will be calculated based on the weighted contribution of four performance programs: (1) successful EHR adoption as measured by the MU program will contribute to 25% of the score, (2) successful PQRS participation, which serves as a “proxy” for quality, will represent 30% of the score, (3) the cost measures associated with the PQRS-reported quality information, also referred to as VBM-measured resource use, will account for 30% of the score and (4) a new clinical practice-improvement category (representing, for instance, expanded access to healthcare with same day appointments, telehealth capabilities, patient safety initiatives) will contribute with 15%.

Questions remain regarding the MIPS calculation, as some programs, like MU, were designed to capture individual measures whereas group reporting is allowed under PQRS. Regardless of the ultimate methodology, the MU and PQRS programs gain longevity and relevance with this new legislation.

For the faithful who were able to keep up with the MU and PQRS programs, well done! Now it is time to embrace MU stage 2 and stage 3 knowing  that successful participation will affect 25% of your grade. Theoretically, lack of participation in the MU program could limit one’s score to 75 points. Unlike the VBM, however, the MIPS score was designed for public consumption, and it will be publicly and transparently published. The MIPS score is probably not the most appropriate measure of radiology quality and efficiency, yet it likely will be perceived as such.

For those who are unsure of their MU and PQRS readiness, there is no need to panic. Re-energize the troops, re-group the old MU/PQRS steering committees and stay informed. Follow and support the efforts of the ACR and keep a watchful eye for MIPS-related updates and the upcoming CMS final rule.