My name is Bob Owens. I am the associate executive director of information technology/CIO for the American Dental Association. (ADA). Again, it is my pleasure to appear today on behalf of the ADA before the Subcommittee on Health Data Needs, Standards, and Security of the National Committee on Vital and Health Statistics (NCVHS). The following points summarize our statement and recommendations as a standards developing organization for achieving the goals intended by administrative simplification:
1. What medical/clinical codes and classifications do you use in administrative transactions now? What do you perceive as the main strengths and weaknesses of current methods for coding and classification of encounter and/or enrollment data?
The coding systems used in dentistry are the Current Dental Terminology (CDT), the Current Procedural Terminology (CPT) , HCFA's Common Procedure Coding System (HCPCS), and the International Classification of Diseases. Encounter and enrollment data are not classified under dentistry at this time.
2. What medical/clinical codes and classifications do you recommend as initial standards for administrative transactions, given the time frames in the HIPAA? What specific suggestions would you like to see implemented regarding coding and classification?
For dental claims, the ADA recommends that CDT, CPT, HCPCS, and ICD-9 codes be adopted for dental administrative transactions.
Recognizing the need for standards in clinical terminology and the limitations of the current coding systems, the ADA engaged in the difficult task of creating a clinical terminology and coding system that will provide the profession with comprehensiveness and varying degrees of utility. We are currently developing a microglossary of the Systematized Nomenclature of Medicine (SNOMED) so that patient history, findings, services and outcomes can be represented accurately. In addition, we are developing a comprehensive glossary of the dental terms. Standardized terminology must have explicit definitions. A collective guide is important for consistent interpretation of terms by the profession and aggregate data analysts.
This work is being paced accordingly with the other agencies of the ADA involved in the development of standards for the Computer-based Oral Health Record and the Computer-based Patient Record.
Given these activities and the requirements of HIPAA, the ADA recommends that the Secretary of DHHS move forward with the adoption of current CDT standards for the specified administrative transactions in the law. In addition, the ADA recommends adoption of standards for clinical transactions and supporting code sets should be deferred until the appropriate frameworks, data dictionaries, cross mappings and harmonization of the current and proposed standards can be fully developed.
3. Prior to the passage of HIPAA, the National Center for Health Statistics initiated development of a clinical modification of ICD-10 (ICD-10-CM), and the Health Care Financing Administration undertook development of a new procedure coding system for inpatient procedures (called ICD-10-PCS), with a plan to implement them simultaneously in the year 2000. On the pre-HIPAA schedule, they will be released to the field for evaluation and testing by 1998. If some version of ICD is to be used for administrative transaction, do you think it should be ICD-9-CM or ICD-10-CM and ICD-10-PCS, assuming that field evaluations are generally positive?
The Association believes that, in addition to the previously mentioned CDT, CPT and HCPCS coding systems, ICD-9-CM should continue to be utilized for administrative transactions with migration towards the upgrade of ICD-10-CM and ICD-10-PCS as they become viable. This assumes continued use of CDT, CPT, HCPCS and their successors.
4. Recognizing that the goal of PL 104-191 is administrative simplification, how, from your perspective, would you deal with the current coding environment to improve simplification, reduce administrative burden, but also obtain medically meaningful information?
Again, the ADA recommends the use of existing coding systems to meet the requirements of HIPAA. The ADA also recommends that the Secretary of DHHS rely on the ADA as one of the four consulting organizations for any future modifications of the coding system(s) used in dentistry.
5. How should the ongoing maintenance of medical/clinical code sets and the responsibility, intellectual input and funding for maintenance be addressed for the classification systems included in the standards? What are the arguments for having these systems in the public domain versus in the private sector, with or without copyright?
The ADA has a long proven successful history in the development and maintenance of dental standards. To be effective, a coding standard must have an experienced organization maintain the system in question. However, it is important to make the coding systems readily available to the general public. When a standard is maintained in the public domain, there tends to bequality control issues.
6. What would be the resource implications of changing from the coding and classification systems that you currently are using in administrative transactions to other systems? How do you weigh the costs and benefits of making such changes?
The current coding systems utilized in dentistry have a long history of use by dentists. To change the systems now would require a great deal of resources in the areas of training and education, hardware and software modifications, and a loss of data compiled based on the current systems.
7. A Coding and Classification Implementation Team has been established within the Department of Health and Human Services to address the requirements of P.L. 104-191; the Team's charge is enclosed. Does your organization have any concerns about the process being undertaken by the Department to carry out the requirements of the law in regard to coding and classification issues? If so, what are those concerns and what suggestions do you have for improvements?
As we stated yesterday, the ADA believes the administrative simplification and cpr coding standards should be addressed separately. The Secretary of DHHS should adopt the existing dental coding standards for administrative processing in the initial HIPAA regulations. This will give the health industry as a whole the necessary time to complete the development, testing and implementation plan for cpr. An attempt to address the cpr coding issues now would be counterproductive to the intent of the administrative simplification under the law.
We thank you for the invitation to address this committee, and look forward to providing further assistance in our roles of HIPAA consultant and an ANSI standards development organization.