Hospitals required to demonstrate Electronic Image Sharing in 2011

Despite the key role that medical imaging plays in patient care, the inclusion of medical images in the Meaningful Use criteria for ARRA funding was supposedly all the way out in 2015.  One would think that that would give a healthcare organization plenty of time for planning, choosing a solution, budgeting and picking a vendor.

In theory, there are a number of ways to support Meaningful Use of images through the Physician Portal.  Whether you believe the best approach is [1] an Enterprise Archive with a UniViewer, [2] a multi-department PACS with its UniViewer, or [3] a continuation of individual department PACS, each with their own viewers; four-plus years would seem to be plenty of time to watch what the early adopters deploy and figure out your own strategy.

I think those four years just disappeared…in a puff.

In a recent article, Keith Dreyer, D.O., Ph.D., included a statement in his conclusion that came as something of a surprise to me.   That statement is worth repeating here in its entirety.  The underlines are mine.

“The Centers for Medicare and Medicaid Services proposed rulemaking of December 2009 suggests that providers will be required to demonstrate cross-provider patient medical data sharing by 2011. Furthermore, at least 80% of patient requests for electronic medical data must be able to be delivered within 48 hours. It is expected that medical imaging will be an important component of these requirements. As the federal government begins to require even more communication among all healthcare providers, the need for standards-based technology will undoubtedly become an integral part of the medical imaging IT infrastructure.”

“By taking a proactive approach and deploying technology such as image sharing applications, your department—and organization—will be better prepared for the impending future.”

Since this admittedly came as a surprise to me, I did a search and came up with an article in Healthcare IT News that listed the actual wording of the December rulemaking that Dr. Dreyer was interpreting.  Sure enough, in # 15 and #17 in the list of 23 Stage 1 Meaningful Use criteria, there appears a reference to “diagnostic test results”, and one can easily agree with Dr. Dreyer that that should be interpreted to include the actual images themselves.

What a timely discovery!

Medical Image (data) Sharing is already a hot subject.  By my count there are already 20 companies pitching some version of electronic Image Sharing…data transfer from site A to site B over a Virtual Private Network (VPN) or through an encryption application over the internet.  In most cases, these products are simply replacing the method of data transfer, replacing CDs with a network.  Most of these solutions fail to address a more subtle problem with data exchange between systems.  That problem is data compatibility.

All PACS systems are largely DICOM-conformant, but that conformance in and of itself does not guarantee data compatibility between different PACS.  Image data formatted by PACS A is not necessarily going to be fully compatible with PACS B just because the data is in the DICOM format.  I’ve already posted a piece on this subject on this web site. These new electronic image sharing products/services must be able to perform bi-directional dynamic tag morphing on the image data being transferred between systems in order to assure compatibility on the receiving end.

What makes Dr. Dreyer’s conclusions regarding electronic image sharing in 2011 so interesting is that they link Image Sharing with the larger subject of Meaningful Use by 2015.

I believe Meaningful Use in 2015 will depend on Ease of Use, and that strongly suggests a single consolidated image data repository and a single UniViewer, and the foundation of that concept is dynamic tag morphing…the ability to make image data from disparate PACS compatible with a single viewer.   So the PACS-Neutral Archive and the Image Sharing System have a very important key ingredient in common…Bi-directional Dynamic Tag Morphing.

There may be plenty of time to build the infrastructure necessary to achieve Meaningful Use of image data in 2015, but there’s no point in overlooking opportunities to build the stepping stones of that infrastructure this year.  An Image Sharing solution that includes the tag morphing application might easily be expanded, step-by-step, year-by-year to become the Neutral Archive an organization will need in 2015.

Picking the right Image Sharing solution, the one that grows into Neutral Archive, means having the bigger plan in place for the Neutral Archive.  Getting from 2011 to 2015 with the least number of dead-ends, restarts, forklifts, etc, means taking the time to build the big plan now.  Thank you, Dr. Dreyer, for providing a more immediate motivation.

What’s it going to take to achieve Meaningful Use of Images?

The other day a friend of mine forwarded to me a link to the Imaging Technology News eNews web site.  My friend encouraged me to look on the left bar of the web page and find the invitation to participate in their current survey.  The question was “Will PACS/RIS meet the meaningful use criteria to qualify for incentive dollars?”  If the survey is still running, you can check out the current results here.

Last time I checked, 33% thought that PACS/RIS would meet the criteria and another 30% thought that there’s a good chance it will.

I’d love to see the demographic of the survey participants, and I’d love to see a list of their assumptions.

I’m among the 30% that responded with a solid “no”, convinced that the PACS/RIS as we know it will not qualify for Meaningful Use, because it simply doesn’t have what it takes, and most likely never will.

If the survey participants gave serious thought to the question, they should have realized that the most critical component of what it takes to sustain Meaningful Use will be “ease of use”.  Most physicians are far too busy to learn and remember how to use more than one image viewer.  Most physicians are far too busy to switch back and forth between multiple viewers to assemble a montage of all the relevant clinical information in a single viewing window.  That’s exactly what will happen if we continue on the present path of developing individual URL links between the Physician Portal and the data elements being stored in each of the specialized departmental PACS, and using those department PACS viewers to view the data.  This approach shouldn’t make sense to IT, and it won’t make sense to the physician users.  So the participants must have been assuming that an all-encompassing Enterprise PACS will emerge, a single PACS that will embody all of the specialized department PACS requirements and thereby become the Uni-PACS.

In my opinion, it is highly unlikely that a current generation Radiology or Cardiology PACS or any other departmental PACS for that matter, will evolve in the next few years into an Enterprise Data Repository capable of managing the patient’s longitudinal record of all clinical information.  I seriously doubt that they will be able to manage all of the image information, much less all of the non-DICOM and non-image data objects.

Managing all of this clinical data is probably the easier part.  The harder part will be providing all of the expected display and processing applications that are specialized for each of the contributing imaging departments.  This is not to say that some of the larger vendors won’t try to become an all-encompassing enterprise PACS, or at least claim to be the Whopper of PACS, but I don’t see that happening.

In my opinion, the more likely scenario will be the Enterprise Neutral Archive fulfilling the role of the Enterprise Data Repository, and the (interfaced or embedded) UniViewer will provide the unified set of viewing tools that the physicians will use to access and view all of a patient’s clinical information, both the image and the non-image data being managed by that Neutral Archive.

Today, more and more Health Care organizations are “getting it”.  They see all of the advantages of separating the “archive” data management applications from the departmental PACS.  And it’s a natural to add a viewer to this new generation Archive.   Sooner or later, each of the PACS vendors will “get it”, and at that moment the push will be on in their R&D groups to further differentiate their department PACS products with the specialized applications unique to that department.  Their PACS will have to become an even better, specialized tool for each department, because the Neutral Archive will have already become the tool of choice for the Enterprise.  Meaningful Use will be much easier to achieve if the physicians know they only have to go to one repository and only have to use one viewing application to assemble all of the relevant clinical information in a single viewing session.  Get it?