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Saturday, July 13, 2013

Can I ask You a MeaningfulUse Question on CDS and Imaging?

This question came in via Ask me a Question. Since 1) I'm on vacation and 2) I've little experience with Radiology workflows, I thought I'd see what crowd sourcing can do to get an answer.  Here is the question:

Hi Keith 
I was wondering if you had any thoughts how a vendor for a Radiology Information System program would implement clinical decision support for MU Stage 2. It seems like the MU CDS rules are geared more towards providers, in that it helps them decide on a course of action depending on a list of variables. However, when a patient arrives in a radiology department the decisions have already been made by the provider. There's not much else anyone in the radiology department can do. To make things even more difficult, the ONC's testing criteria "Test Procedure for §170.314(a)(8) Clinical decision support" states over and over that each CDS intervention be automatic and based on the patient's problem, medication, medication allergy, demographics, labs, and vitals. Like I said, all of those variables have already been sorted out by the time a patient has arrived in the radiology department, so do you have any thoughts on how a radiologist can incorporate CDS?

I have to agree that the rules are more geared towards traditional providers.  I also seem to remember a few cases where there were exceptions available when a provider did not directly interact with a patient, but I don't believe that was addressed in CDS.  And while I could look it up, I'm on vacation ;-)

So let me see what you can do to help this reader.  Please respond in comments below.


  1. Keith, many radiology groups with non-certified RIS systems have implemented certified EMR systems. I have worked with a number radiology practices that implement the EMR in a way that requires minimal provider interaction (since they do the majority of their work in the RIS), yet meets the requirements of MU Stage 2. Obviously this requires interfaces to exchange data, but also requires some human interaction. Where the EMR is not able to import all the necessary discrete elements of data, a Medical Assistant enters them. The provider signs the documentation later.

  2. CDS is part of the Base EHR, so the radiologist will need to possess CDS even if they do not use it or qualify for an exemption. Why don't they look implementing CDS for the practice guidelines created the American College of Radiology - they can pass CDS if they can show one intervention each for
    Problem list; Medication list; Medication allergy list; Demographics; Laboratory tests and values/results; and Vital signs as well as one combination of two or more of the above categories. Just because the ordering physician should have checked their order through CDS does not mean the performing radiologist shouldn't as well.

    1. Not quite. A certified EHR must support that capability, but to earn payments, the EP must implement 5 rules supporting the CQMs under the incentives rule. There are enough radiology related measures that it can be done though.