D'Arcy Gue

Three Ways to Improve Your Meaningful Use / MIPS Stage 2 Preparations Post ICD-10 Delay

April 22, 2014

Meaningful Use / MIPS 4 Minute Read

For most of the last 18 months, healthcare IT professionals have been struggling with resources to meet competing legislative priorities. ICD-10 was scheduled for implementation on October 1, 2014 and the beginning of Meaningful Use / MIPS Stage 2 was scheduled for the same date. Both implementations required substantial IT resources (often the same ones) and carried substantial financial penalties for missing the deadlines.

At the beginning of April, Congress provided a reprieve by delaying the implementation of ICD-10 for (presumably) one year. Unfortunately, this wasn’t the delay many would have preferred.  A number of CIOs have expressed a preference that the Meaningful Use / MIPS implementation was the one that should have been delayed.  Now that this preference is water under the bridge, what should hospitals be doing with the looming deadline for Meaningful Use / MIPS?

Re-prioritize both IT and Operational resources.Meaningful Use / MIPS organization

With the delay of ICD-10, it makes sense to shift resources in favor of Meaningful Use / MIPS. It certainly doesn’t make sense to delay ICD-10 implementations and testing by a whole year, but clearly a strategic rethinking and re-prioritization is in order.

SNOMED implementation.

The stage 2 standards for Meaningful Use / MIPS require a common dataset for all summary of care records, and that dataset includes SNOMED-CT for specifying patient problems.

SNOMED-CT (Systematized Nomenclature of Medicine – Clinical Terms) is generally considered the most comprehensive clinical healthcare terminology in the world. It contains far more clinical findings (~ 100,000) than ICD-9 (~14,000) or ICD-10 (~68,000). Many clinicians find SNOMED vocabulary superior for their needs – documenting clinical conditions. Both ICD code sets are exactly what the name describes – Classifications. They group diseases into statistical groups, including “non-specific” groups like:

  • I51.9Heart disease, unspecified
  • I52*Other heart disorders in diseases classified elsewhere

I’ve never heard a clinician say to a patient, “You have ‘Unspecified Heart Disease.” That’s not a disease state, but a disease classification.  That classification and the even more confusing “Other heart disorders in diseases classified elsewhere,” are really about reporting and grouping patients into meaningful strata for reimbursement and analysis, not about documenting the clinical condition of the patient. There is also the presumption that a clinician picking out ICD codes understands coding rules and conventions, e.g. he/she has to understand the specific heart disease codes and the diseases classified elsewhere in order to properly understand the use of these two example codes.

The relevant SNOMED codes, by comparison, are more straightforward and organized in a hierarchical tree that mirrors the way clinicians think. The terms were designed specifically with clinical documentation in mind and as a result, the codes selected are much more flexible and descriptive of actual clinical findings than the ICD codes.

Adopting SNOMED-CT codes for clinical documentation is certainly a major project. However the benefits to documentation (and by extension coding and patient care), and the requirement for SNOMED codes in certain Meaningful Use / MIPS transactions make it a relevant certainty that SNOMED implementation should be high on the list of most institutions between now and October 1.

Clinical Documentation Initiatives.

Documentation matters. In addition to its obvious and critical role in patient care, the patient chart serves as a legal document, a quality tool, a compliance tool, and certainly impacts coding, billing and reimbursement. Many hospitals have already discovered the value of an active clinical documentation improvement (CDI) program in improving all of the items above.

Some hospitals (including the majority of our clients) are taking their CDI initiative to a much higher level, by using the process as the core educational vehicle for providers on ICD-10 and SNOMED education issues. There is no reason that CDI reviewers can’t start querying and educating providers now to provide the level of detail required for ICD-10 diagnosis and procedure coding. Once physicians have been better educated on the level of documentation required for ICD-10, coders can more accurately code charts in both ICD-9 and ICD-10, and the organization can make a much more informed estimate of the financial impact of ICD-10 using these charts. For more details on those potential financial impacts, see our revenue cycle series, here.


The additional year we’ve been given on ICD-10 doesn’t make hospital’s Meaningful Use / MIPS work any easier, but it does provide some time to implement EHR systems, SNOMED terminology, and to further educate providers on documentation issues.

Phoenix Consultants are working every day with clients just like you to implement SNOMED, Meaningful Use / MIPS, and provider education and training programs.  If you’re interested in speaking to one of our consultants, let us know!



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