MU Stage 3 Imaging Comments

Summary: Early this year comments were submitted for MU Stage 3, addressing viewing, downloading and transmitting images and radiation dose information.

Long Version.

I should have posted this back in January when I submitted my own comments, but better late than never.


The HIT Policy Committee put out a Request for Comment Regarding the Stage 3 Definition of Meaningful Use of Electronic Health Records (EHRs), Docket ID: HHS-OS-2012-0007, which was just that, an RFC, and not a proposed rule making. Within it, several issues were raised of relevance to the image sharing community, including the following that I considered it was important to comment on:

• Moving Stage 2 Menu Item to Core, regarding "imaging results consisting of the image itself and any explanation or other accompanying information are accessible through Certified EHR Technology"
• With respect to View, Download and Transmit (VDT), a question was asked about exploring the readiness of vendors and the pros and cons of including certification for actual images, not just reports
• With respect to View, Download and Transmit (VDT), a question was asked about exploring the readiness of vendors and the pros and cons of including certification for radiation dosing information from tests involving radiation exposure in a structured field so that patients can view the amount of radiation they have been exposed to

If you are interested in reading my comments, you can find them in the docket as HHS-OS-2012-0007-0082. I won't repeat them here, though I did just notice a typo (IID will be tested at the 2014 connectathon, not the 2015 connectathon).

Other folks also made relevant comments, including MITA (HHS-OS-2012-0007-0559), DICOM (HHS-OS-2012-0007-0575), and the ACR ITIC (HHS-OS-2012-0007-0571).

The government's site allows you to search the contents of the docket to find relevant comments.

For example, if you search on the word "DICOM", you will find in addition to the aforementioned, a bunch more from various vendors and facilities, some of which are generally supportive (e.g., Aware, Green Leaves, ACR, Siemens, lifeIMAGE, AAO, ACC), some less so (e.g., Philips, Heart Rhythm Society, Boston Medical Center, AAFP) and even some still completely opposed, for example, to providing images to patients (Intuit Health).

Even the EHRA comments this time, though still expressing concern, were not relentlessly negative; confirming perhaps, that the strategy of using a link and having the images supplied by a different type of system, does indeed assuage the EHR vendors concerns expressed last time around.

One can dig deeper, e.g., by looking for all comments related to "image", though one gets a lot of spurious hits. But for example, one finds individual facilities expressing concern. For example Montefiore, who are concerned about the need for integration with radiology practices, and that "interpretation of the image is not within the expertise of the orderer".

There does seem though, to be a positive trend in the direction of including imaging more comprehensively and in a standard manner in Stage 3, though there is certainly a long way to go yet. Who knows who is listening, whether they have an open mind, and whether any proposed rule making will goes as far as imaging-centric folks like me might hope (not to mention what standards, if any, might be required).

David