"Meaningful Use" criteria require problem lists in ICD-9 or SNOMED

As we discussed in previous posts here and here, the "stimulus bill" passed by Congress earlier this year increases Medicare and Medicaid payments to physicians and hospitals who are "meaningful users" of electronic medical records (EMRs) in coming years.

The linchpin to the payments is the definition of "meaningful use", which the law mandates that the Department of Health and Human Services (HHS) define. The law also mandated the formation of the Healthcare Information Technology (HIT) Policy committee, and it is this committee that is currently conducting hearings into what the criteria for "meaningful use" should be. Ultimately, HHS will define meaningful use through a rulemaking process similar to the one that led to the mandate to switch to ICD-10-CM.

Well, the latest "matrix" (warning: pdf) of meaningful use criteria stipulate that the EMR must maintain problem lists in either ICD-9 or SNOMED.

We think they are both terrible choices. Problem lists maintained in either system are not likely to be very meaningful at all.

Doctors: ICD-10 Switch Inhibits "Meaningful Use" of EMRs

For a brief introduction to federal incentives for adoption of electronic medical records (EMRs), see yesterday's post.

In response to a request for comments on proposed rules for meaningful use, over 80 physician organizations joined forces behind a letter to the Office of the National Coordinator for Health Information Technology (ONCHIT). This letter outlines the unanimous opinion of these organizations on what the "meaningful use" criteria for EMRs should be.

The 80 organizations include the American Medical Association, the American Academy of Family Physicians, the American College of Obstetricians and Gynecologists, the American College of Radiology, the American College of Surgeons, the American College of Physicians, and numerous state medical societies.

In an attachment to the letter, these doctors' organizations note that in setting the timing of EMR implementation, ONCHIT should ...Factor in the Implementation of Version 5010, ICD-10, and Other Related Compliance Deadlines.

The attachment goes on to say:

The health care industry, including physicians, will be migrating to the next version of HIPAA electronic transactions standards,Version 5010, by January 1, 2012. Moreover, the transition from using ICD-9 to ICD-10 codes must occur by October 1, 2013 which is expected to be an even more complex undertaking than the adoption of the first version of HIPAA standards (4010) and the transition to use of the National Provider Identifier (NPI). The implementation timeframe must factor in vendor, physician, and other health care partner readiness for all of these significant transitions that will occur simultaneously with the incorporation of HHS’ recommended standards for qualifying EHRs.

Which ultimately means that physicians, in addition to hospitals, expect the switch to ICD-10-CM to slow them down significantly with respect to becoming "meaningful users" of EMRs.

Hospitals: ICD-10 Switch Inhibits "Meaningful Use" of EMRs

The "stimulus package"--more formally known as the American Recovery and Reinvestment Act of 2009--promises doctors and hospitals increased reimbursement from Medicare and Medicaid if they become "meaningful users" of electronic medical records (EMRs). Of course, the Act leaves open the definition of meaningful use, leading to yet another rulemaking process similar to the one that produced the mandate to switch to ICD-10-CM.

In its comments to the Office of the National Coordinator for Health Information Technology (ONCHIT), the American Hospital Association (AHA) correctly recognizes that the switch to ICD-10-CM will drain away resources from their efforts to become meaningful users of EMRs. In response, the AHA says that ONCHIT should slow down and lighten the criteria for "meaningful use."

The AHA comments (warning: pdf) say:

Staging the requirements and use levels in the definition also should recognize other HIT initiatives already underway and the likely vendor and workforce constraints hospitals may face. Hospitals are required to move to the new X12 Version of 5010 HIPAA standards in 2010 and ICD-10 in 2013. The AHA also is concerned that vendors will not be able to improve, test, implement and support HIT systems in hospitals nationwide due to the increased and simultaneous demand for HIT services and products. Vendor and hospital IT workforce capacity constraints should be considered as well.

In other words, the switch to ICD-10-CM will pull resources away from hospitals' ability to achieve meaningful use of EMRs.