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Tuesday, July 13, 2010

Procedure Codes in Standard Final Rule

The Meainingful Use Standards rule went on display today.  In reviewing the rule this morning, I found a small but significant error.

I found what I believe is an error in one of the responses on page 169 of the public display copy to comments on rule text. The document states:

Response. We understand that most current EHR technology already includes the
CPT-4 code-sets, and we believe that this indicates that the licensing costs are not
prohibitive. Regardless, we have adopted an alternative standard to CPT-4, SNOMEDCT
®, which is freely available.

However, my review of the standards selected under that section indicate that SNOMED-CT should be replaced with ICD-9-CM, as indicated by the following:

From the text on display:
Final Rule Text:
§170.306(d)
(1) Enable a user to create an electronic copy of a patient’s
clinical information, including, at a minimum, diagnostic test
results, problem list, medication list, medication allergy list,
and procedures:
(i) In human readable format; and
(ii) On electronic media or through some other electronic
means in accordance with:
(A) The standard (and applicable implementation
specifications) specified in §170.205(a)(1) or §170.205(a)(2);
and
(B) For the following data elements the applicable standard
must be used:
(1) Problems. The standard specified in §170.207(a)(1) or, at a
minimum, the version of the standard specified in
§170.207(a)(2);
(2) Procedures. The standard specified in §170.207(b)(1) or
§170.207(b)(2);
(3) Laboratory test results. At a minimum, the version of the
standard specified in §170.207(c); and
(4) Medications. The standard specified in §170.207(d).
(2) Enable a user to create an electronic copy of a patient’s
discharge summary in human readable format and on
electronic media or through some other electronic means.


§170.207 Vocabulary standards for representing electronic health information.

(b) Procedures. (1) Standard. The code set specified at 45 CFR 162.1002(a)(2).
(2) Standard. The code set specified at 45 CFR 162.1002(a)(5).

And from 45 CFR 162.1002 found at http://cfr.vlex.com/vid/162-1002-medical-data-code-sets-19931702
162.1002 - Medical data code sets.

...
(2) International Classification of Diseases, 9th Edition, Clinical Modification, Volume 3 Procedures (including The Official ICD9CM Guidelines for Coding and Reporting), as maintained and distributed by HHS, for the following procedures or other actions taken for diseases, injuries, and impairments on hospital inpatients reported by hospitals:
(i) Prevention.
(ii) Diagnosis.
(iii) Treatment.
(iv) Management.

...
(5) The combination of Health Care Financing Administration Common Procedure Coding System (HCPCS), as maintained and distributed by HHS, and Current Procedural Terminology, Fourth Edition (CPT4), as maintained and distributed by the American Medical Association, for physician services and other health care services. These services include, but are not limited to, the following:
(i) Physician services.
(ii) Physical and occupational therapy services.
(iii) Radiologic procedures.
(iv) Clinical laboratory tests.
(v) Other medical diagnostic procedures.
(vi) Hearing and vision services.
(vii) Transportation services including ambulance.

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