ehr onc final certification - Department of Health Care Services

Response. The comments are correct in that ICD-9-CM is primarily used for
billing and administrative purposes. SNOMED-CT® is offered as an alternative standard
that will support more clinical descriptions of patient problems or conditions. We believe
that with the adoption of both SNOMED-CT® and ICD-9-CM, healthcare providers
should have adequate coverage for patient diagnoses and conditions. We are discouraging
the use of free text for documenting problem lists since this will limit the usefulness of
problem lists for clinical reminders, decision support and other patient safety and quality
reporting.
Comments. Several commenters recommended that only SNOMED-CT® be
adopted, or alternatively, that we expressly indicate an intention to move away from ICD-
9CM and ICD-10 in the future. Another commenter recommended against the adoption
of SNOMED-CT® because the commenter felt that our adoption of SNOMED-CT®
would require eligible professionals and eligible hospitals to use both ICD-9-CM and
SNOMED-CT®. One commenter recommended that a publicly vetted and HHS
approved standard mapping between ICD-9-CM and SNOMED CT® should be made
available at the public’s expense.
Response. We agree conceptually that a single standard for clinical information
would be desirable in the long term. However, presently both ICD-9-CM and SNOMED-
CT® are used by EHR technology to code clinical information, and adopting both would
provide users with additional flexibility. Moreover, we anticipate that as meaningful use
objectives and measures evolve over time, we will receive additional public input and
experience related to these standards and may eventually be able to adopt only one
standard.
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