ehr onc final certification - Department of Health Care Services

the patient has been discharged. Another commenter requested that we further clarify the
subset of relevant procedures that should be included. The commenter explained that it
believed including CPT-4 or ICD-9 codes seemed inappropriate for clinical summaries
since these codes are used for “procedures as billed,” and the commenter further asked
whether we intended to include only major procedures.
Response. We clarify that the adopted standard pertains to the vocabulary that
would be used to express procedures, regardless of how they are selected, or included.
Comments. A commenter stated that with an X12 837 standard transaction, ICD-
9-CM is accompanied by a flag that indicates whether this code is being used to bill for
services meant to eliminate a diagnosis. The commenter stated that neither the CCR nor
the CCD support such a flag, and concluded that there was no way to know whether ICD-
9-CM codes used in either CCD or CCR could accurately convey a patient’s problems.
The commenter also recommended SNOMED-CT® should be used with a CCD, because
ICD-9 codes have too little clinical detail. Another commenter favored the use of
SNOMED-CT® as well and stated that SNOMED-CT® would be more clinically
accurate and better suited for our purposes. Another commenter encouraged us to adopt
the Current Dental Terminology.
Response. The diagnoses included within the patient summary record are meant
to convey clinically relevant conditions as recorded in Certified EHR Technology’s
problem list, rather than billing diagnoses. While we agree that SNOMED-CT® provides
additional clinical detail, this is often not available in current practice. Furthermore,
while its use is not precluded, we do not believe that it is necessary to adopt the Current
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