1. What medical/clinical codes and classifications do you use in administrative transactions now? What do you perceive as the main strengths and weakness of the current methods for coding and classification of encounter and/or enrollment data?
Answer: We are currently using ICD-9-CM, DSM IV, CPT. There are numerous strengths in the current methods for coding and classification of encounter and/or enrollment data. One of the most obvious strengths is the historical relationship. The biggest weakness is in expressing the purpose of visit for non-MDs.
2. What medical/clinical codes and classifications do you recommend as initial standards for administrative standards for the administrative transactions, given the time frames in the HIPAA? What specific suggestions would you like to see implemented regarding coding and classification?
Answer: We would like to see ICD-10-CM and ICD-10-PCS adopted for all clinical activity. If the USA is destined to have two different procedural coding systems, it would be beneficial to have a crosswalk between systems.
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 transactions, do you think is should be ICD-9-CM or ICD-10-CM And IDC-10-PCS, assuming that field evaluations are generally positive?
Answer: If he evaluations are positive, it should be ICD-10-CM and ICD-10-PCS.
4. Recognizing that the goal of P. L. 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?
Answer: Develop and implement an automated clinical vocabulary which could assign the codes. "Super coders" could be employed to maintain the coding within the vocabulary.
5. How should the ongoing maintenance of medical/clinical code set and the responsibility, intellectual input and funding for maintenance be addressed for the classification systems in the public domain versus in the private sector, with or without copyright?
Answer: Not Applicable
6. What would 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 if making such changes?
Answer: The crosswalk development would be the highest priority. If these were not developed commercially it would be personnel resource intensive to develop within the VA. Due to the vast research activities in the organization the transactions would be imperative.
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 improvement?
Answer: Department of Veterans Affair is a member of this team.
Additional Questions for NCVHS Hearing on Coding and Classification Systems
1. Can one system serve most if not all purposes e.g. clinical care surveillance, quality assessment/improvement, clinical research, billing/management? If not, which systems can serve most of these functions?
Answer: A good clinical vocabulary linked where necessary to different coding and classification systems could serve most of these purposes. SNOMED (Systematized Nomenclature of Human and Veterinary Medicine) could serve most of these functions, however, the many different combinations of SNOMED codes for one disease or procedure would make if extremely difficult to teach.
2. Is it administratively simpler to use the same disease classification for administrative transactions And for statistical reporting?
Answer: Yes
3. To what extent do you feel that your discipline and practice settings are well represented by current systems for coding health conditions, diagnoses, services and procedures in administrative and financial transactions?
Answer: VHA provides many services which are not covered in either ICD or CPT. These are non-physician services which are beneficial to a patient's health status.
4. What issues do you encounter linking data coded with different classification systems and trying to crosswalk between (or among) classification systems?
Answer: The classification systems are to disparate; they focus on different issues. One is narrowly focused, the other is broadly focused and vice versa, thus you end up with a very messy crosswalk.
5 What are the impact and implications for current (and emerging) medical/clinical classification systems as we migrate towards computer-based patient records (CPR)? To what extent can the major classification systems currently in use service, in part, as vocabulary for the CPR, and if another system is recommended as the vocabulary for CPR, how can we assure that it crosswalks relatively easily to the classification systems currently used in administrative and financial transactions.
Answer: The different systems in use may lose some of the "power"" as a true clinical vocabulary comes into being. All major classification systems currently in use should be used in any vocabulary for the CPR. Crosswalking relatively easily is subjective; however it will be essential to trend data historically.
6. For presenters recommending a particular coding or classification system, what is the market acceptance for the system and current scope of use? What are mechanisms for low cost distribution?
Answer: Not Applicable
7. How might the NCVHS work with the Department to assure that the United States coordinates development of an international medical dictionary, classification/coding system etc., including the terms, a process to keep continuously such terminology updated, and a server to deliver content to whoever needs access?
Answer: Not Applicable
8. Is it practical to move to a single procedure classification systems on the timetable required for initial implementation of administrative standards or should the standards continue the current practice of requiring different coding systems for the ambulatory and inpatient sectors?
Answer: It is not only practical it is necessary in order to measure outcomes and review across a continuum. Given that ICD-10-PCS is totally new, we would encourage a phased approach. Begin with inpatient (lower volume, etc) then hospital based ambulatory care, and then physician/clinician.
9. If a medical/clinical code set or classification system is selected as a standard, should providers be able to use all the available codes within the set or system or should those requiring the information (e.g. payers) be allowed to restrict reporting of certain codes?
Answer: Codes should not be restricted, however the provider type should be designated.