I finally took time today to peruse the Meaningful Use Final Rule document (Federal Register / Vol. 75, No. 144 / Wednesday, July 28, 2010 / Rules and Regulations) – note I said “peruse” as I couldn’t possibly read and digest all 276 pages of it!
The Government View
I understand from the document that the Meaningful Use criteria have now been broken down to three “Stages” and the only defined stage at this point is Stage 1. The document states the goal for Stage 2 as (to) “expand upon the Stage 1 criteria to encourage the use of health IT for continuous quality improvement at the point of care and the exchange of information in the most structured format possible, such as the electronic transmission of orders entered using computerized provider order entry (CPOE) and the electronic transmission of diagnostic test results (such as blood tests, microbiology, urinalysis, pathology tests, radiology, cardiac imaging, nuclear medicine tests, pulmonary function tests, genetic tests, genomic tests and other such data needed to diagnose and treat disease).”
Note that I have bold faced potential imaging services listed as examples. So, in effect, Meaningful Use is now contemplating the inclusion of electronic imaging in Stage 2. This seems to be an improvement over the initial guidelines that had imaging at the tail end of MU.
I would subscribe that imaging is way out in front of MU in terms of the ability to apply it today. Take the case of Radiology PACS (Picture Archiving and Communications System). In the United States, Radiology PACS is relatively well-saturated in all but the smallest of facilities. Most current-day PACS offer some form of web services that enable external users such as physicians to remotely access their patient’s exams. Hence, the general practitioner that referred their patient to the hospital for a CT to rule out a tumor can access the images from their office, and potentially even share them with the patient.
Alternatively, the patient may have received a CD with their study on it if the physician had requested the patient bring a copy of the study with them on their next visit. The CD has a built-in viewer, so the physician does not require anything more sophisticated than a PC to view the study.
Recently, several companies have introduced technology to improve accessibility while eliminating the CD. Such systems can import the CD to a server and make it available electronically, as well as import the study directly from the imaging equipment or PACS and eliminate the CD altogether.
Most current PACS also support API’s (Application Programming Interface) that enable an EMR (Electronic Medical Record) to link a URL and launch an image viewer for EMR studies that include imaging. If a physician can access the EMR, they most likely can see selective images for their patient.
I have recently been playing around with Goggle’s Health record. I have successfully imported DICOM images to the cloud using their import tool, thus establishing the prospect that a facility could directly link their imaging records to such patient health record sites, and thereby enable the patient to have a copy of their imaging studies.
Most of the Stage 1 measures to meet the objectives provide for some percentage of patient records electronically communicated. I would make the argument that imaging is more than capable of doing this already. The question is the value in doing so. While it is clear that the priority and greater value is in delivery of diagnostic results, such as the pathology or radiology report, there are many instances where the image is of value in addition to the report. EMR accessibility will bear this out, given the relative ease in interfacing PACS to the EMR. I further wonder about the value of the ability of the EMR to capture the percentage of time the image was accessed from the EMR when the report was viewed. Perhaps this could be a powerful justification for inclusion of imaging in MU if this information were captured and published.
Given the advanced state of electronic image accessibility, shouldn’t it be possible to make the case for inclusion in Stage 1 of MU and improve the likelihood of compliance and funding? Anyone care to comment? Perhaps it’s time for me to draft another open letter to Dr. Blumenthal?!