Clinical Decision Support for. Medical Imaging 12-1pm

Transcription

1 Work Group on a Standard Imaging Order Clinical Decision Support for Update on activities July 23, 2015 Medical Imaging 12-1pm

2 Agenda 1. Welcome 2. A little background refresher 3. Current progress 4. Next Steps -how to stay engaged 2 Work Group on a Standard Imaging Order July 23, 2015

3 3 A little background refresher

4 Our Work Group The Work Group on a Standard Imaging Order was formed at the request of the eordering Coalition The Work Group started when Clinical Decision Support for the ordering of advanced imaging moved from an option to a legislative reality The Work Group co-chairs were named by the eordering Coalition 4

5 eordering efforts gained a legislative solution in 2014 Protecting Access to Medicare Act of 2014 H.R.4302 SGR patch Delayed ICD-10 Section 218: Mandates the consult of appropriateness criteria in the ordering of any advanced imaging exam -Referring clinicians are required to use CDS but only the provider who does the imaging study will be denied payment if there is not decision support verification. -Leaves it up to the Medicare agency to set the rules for how the process for submitting claims with decision support verification is done and what guidelines content is acceptable. 5

6 PAMA Specifics on CDS 1. Mandates that physicians and other providers consult with appropriate use criteria (AUC) when ordering advanced diagnostic imaging (MRI, CT, NM, PET) for their Medicare patients 2. Rendering facilities and interpreting physicians must provide documentation that AUC was consulted in order to be paid by Medicare 3. The consultation requirement is effective on January 1, Ordering professionals identified as outliers versus their peers will be subject to prior-authorization beginning on January 1, Claims affected: PC, TC, Global, and HOPPS 6. Exclusions: Emergency services, inpatient services (Part A) and significant hardship (case-by-case; e.g., rural without sufficient internet access) 6

7 More PAMA Specifics on CDS Appropriate Use Criteria: criteria to assist in decision making that are developed or endorsed by National Medical Specialty Societies or other Provider-Led entities that are, to the extent feasible, evidence based; No later than November 15, 2015, HHS shall via rulemaking specify AUCs only from those developed or endorsed by National Medical Specialty Societiesor other Provider-Led Entities. Not later than April 1, 2016 (and annually thereafter), HHS will identify an initial list of Qualified Clinical Decision Support Mechanisms HHS shall identify on an annual basis no more than 5% of Ordering Professionals who are Outlier Ordering Professionalswith respect to Applicable Imaging Services. This determination is made using not less than two years of data, beginning with 2017 data Beginning January 1, 2020, HHS shall require prior authorization for the ordering of Applicable Imaging Services by an Outlier Ordering Professional 7

8 Why is this so hard? Components of an Order Order number (linked to accession number) no common standard Patient demographics matching criteria ( First, Las, DOB), including address, method of contact (phone, , etc) Guarantor information - Payer information no common standard CDS score no common standard Exam to be performed no common standard Clinical information, including reason for the exam somewhat standardized Referring and CC physician information NPI standard Valid physician electronic signature Exam priority limited standard Order status (new, reschedule, etc) limited standard Date -standard 8

9 The Life of an Order Order of steps can vary by provider, image center or hospital, and type of order. Adding CDS data to this process today would be largely manual and subject to error. Physician/ Staff ENTER INFO SAVE Physician/ Staff Physician SIGN SUBMIT Physician Hospital or imaging ctr SCHEDULE CLINIICAL REVIEW Radiologist Imaging Center/ Third party PRE- AUTHORIZE CREATE REPORT Radiologist Fax, HL7 DELIVER REPORT 9

10 Evidence-Based Medicine Cycle Patient-Specific Clinical Indicators Identified in EMR or CPOE Patient-Specific Appropriateness Scores Returned Order Placed Order Imaging Procedure Requested by Procedur Physician e Procedure Conducted Improved Care, Lower Costs Ordering Feedback Received by Physician Incremental Rule Developed Clinical Outcomes Analyzed Analytics Reviewed If: then 10

11 Bottom Line for the Work Group Create an imaging electronic order standard that can be utilized consistently throughout the industry for the placement of imaging orders, both high tech (CDS required) and low tech orders. Job One the ability to electronically move the CDS code or number from the ordering provider to the rendering provider allowing capture for the inclusion on the claim. Ensure that the electronic order is: Accurate, transmittable, efficient and printable 1 1

12 Time Check CDS requirement goes into effect January 1,2017 for all advanced imaging Means technology should be tested and usable by October 1, 2016 Means standard should get to all vendors by October 1, 2015 Means standard is developed, understood and accepted by CMS by March,

13 1 3 Current Progress

14 Areas of Effort Define the order and process: Work with IHE to modifying the current Radiology Scheduled Workflow Profile to include the required CDS data. Add support of CDS information as well as other improvements to standardize overall order content and format. Mechanisms and Standards for Data Exchange: Working to determine the most efficient and least costly way to send and receive order information and reports Dictionaries and Informatics: Work to establish standard dictionaries for key data elements wherever possible. Work with CDS vendors to provide this information in a consistent fashion via a query of the CDS number. 1 4

15 Standards-Based Solution The Integrated Health Enterprise (IHE) organization was identified as the best alternative to define a standard process for the interaction and delivery of Decision Support. CDS and EMR vendors were solicited for involvement with the IHE definition of the approach which recently completed and released for public comment. Two different Profiles working in conjunction to complete the entire workflow (PCC and Rad IT) Profiles entering public comment phase and will be ready for testing / implementation in time for 01/

16 IHE: A Framework for Interoperability A common framework for harmonizing and implementing multiple standards Application-to-application System-to-system Setting-to-setting Enables seamless health information movement within and between enterprises, regions, nations Promotes unbiased selection and coordinated use of established healthcare andit standards to address specific clinical needs

17 IHE Profile Cycle Stages Membership Status Open Date Close Date Learn More Call for Proposal Open July, Aug =Radiology_Proposals_ Proposal Selection IHE Profiles drafted in IHE Committees Closed n/a 25 Oct =Radiology Closed Nov 12, Feb 2015 < ditto > Public Comment Open 27 Feb March mework/public_comment.cfm Trial Implementation Published IHE Connectathon Registration IHE NA Connectathon Dates Open n/a May mework/index.cfm Open Aug 2015 Oct /index.cfm Open Jan 2016 Feb 2016 < ditto > Thank you to Chris Lindop for this content Dates are subject to change Please check wiki.ihe.net and click on Radiology 17

18 Current IHE status Patient Care Coordination Proposal(PCC) Was submitted to and accepted by the IHE pport_for_radiology Author is Chris Lindop Public comment period completed, profile being finalized with anticipated release in August CDS Order Appropriateness Tracking (CDS-OAT) Was submitted to and accepted by IHE Authors are John DeLong and Teri Sippel-Schmidt Public comment period completed Final profile published in June 2015 Providers have joined IHE Guidance from IHE members has been strong 42

19 Standards-Based Solution CPOE Patient Care Coordination IHE Profile Scope Interaction with Decision Support AU C #1 AU C #2 AU C #3 AU C #n Decision Support Mechanism Radiology IT IHE Profile Scope Fax Radiology Information System Billing System CMS Communication of Decision Support 19

20 Basic CDS Radiology Profile We now have the pathway defined. We are still missing the data definition from CMS

21 Some members of eordering signed on to a CMS letter in December 21

22 The letter gained us a meeting in March We want to work with CMS to help ensure the successful implementation of section 218(b) of the Protecting Access to Medicare Act (PAMA) of 2014: Efficient Useable Reliable Consistent We are here, not to discuss the clinical aspects of CDS, but rather the mechanics of its implementation. 22

23 Imaging Orders Electronic Requisition HL7 23

24 The TypicalImaging Order Paper Requisition 24

25 The final step CMS

26 Our Request There needs to be a common way to communicate CDS information: For electronic orders: Automate the transmit of CDS information from the ordering provider to the rendering provider(s) Automate the transmit of CDS to the claims generation/revenue cycle management system For faxed (paper) orders: Must include the CDS information on the paper The order intake system must be able to ingest the CDS information from the paper order Transmit the CDS to the claims generation/revenue cycle management system, either electronically or through some other means, i.e. print it on the diagnostic report to allow data entry into the RCM or billing system. 26

27 Our Recommendation 27

28 Current Status Proposed MPFS Rule Appropriate Use Criteria: The AUC must be developed or endorsed by national medical societies or other provider-led entities and be evidence-based. HHS will issue rules by 11/15/15 to designate AUCs Applications are expected to be submitted by 1/1/2016 Approvals of AUC s in expected June 2016 (approval good for 6 years) Qualified Decision Support Mechanisms: We anticipate that the initial list of specified applicable CDS mechanisms will be published sometime after the CY 2017 PFS final rule (Nov. 2016). Open Items still to be addressed: Format and content of CDS Identifier/information to be submitted with the claim. To whom (if anyone) can the ordering provider delegate the task of obtaining the decision support identifier? 32

29 Areas of Effort Dictionaries and Informatics: Work to establish standard dictionaries for key data elements wherever possible. Work with CDS vendors to provide this information in a consistent fashion via a query of the CDS number. The ONC has published suggested code set (RadLex) for procedure codes.

30 Areas of Effort Mechanisms and Standards for Data Exchange: Working to determine the most efficient and least costly way to send and receive order information and reports As it turns out the standards for data exchange are interwoven into the IHE initiative. There is a need for a one to many connectivity solution. However, it is probably naive to there will be a single industry platform, rather it is expected that 2 to 4 vendors will emerge offering this connectivity. However, development will be dependent on data exchange standards.

31 Next Steps

32 IHE Profile Cycle Stages Membership Status Open Date Close Date Learn More Call for Proposal Open July, Aug =Radiology_Proposals_ Proposal Selection IHE Profiles drafted in IHE Committees Closed n/a 25 Oct =Radiology Closed Nov 12, Feb 2015 < ditto > Public Comment Open 27 Feb March mework/public_comment.cfm Trial Implementation Published IHE Connectathon Registration IHE NA Connectathon Dates Open n/a May mework/index.cfm Open Aug 2015 Oct /index.cfm Open Jan 2016 Feb 2016 < ditto > Thank you to Chris Lindop for this content Dates are subject to change Please check wiki.ihe.net and click on Radiology 32

33 Get involved in the Connectathon! Interested vendors should attend a session to learn participation requirements for the January IHE Connectathon and the demonstration project at RSNA <> CPOE <> CDS <> RIS <> EHR <> Reporting <> Billing <> EDI <> August 4, 2015 Led by Teri Sippel Schmidt Julie for the invite

34 Support our efforts with CMS! eorderingmembers please sign on to our latest communication Join the eordering Coalition Communicate with CMS comment on the proposed annual rule

35 Help us improve! What are we missing? Who are we missing?

36 Work Group Contacts Co-Chair: Julie Pekarek, Merge Healthcare Co-Chair: Steve Fischer, Consultant and CDI Emeritus Thank You