Disconnect between the introduction of ICD-10 (set for FY 2014) and meaningful use rules that do not consistently indicate ICD-9 as a valid alternative considering that during FY/CY 2013 ICD-9 is still widely in use and not yet an accepted coding system for payers. � The 2014 Edition rules allow for ICD-10 for procedures and diagnosis, but not ICD-9 for use in various criteria.
� Clinical Quality Measures (CQM) sometimes reference SNOMED only, ICD-10 only, include ICD-9 or do not include ICD-9, or list all three as a valid value set. For example (not exhaustive):
o NQF147 "Diagnosis, Active: Hospital Measures-Acquired immune deficiency syndrome" value set references ICD-10 only.
o NQF469 �Diagnose, Active: Livebirth� and �Diagnosis Active: Liveborn Born in Hospital� value sets reference SNOMED only
o NQF716 �Diagnosis, Active: Liveborn Born In Hospital", �Diagnosis, Active: Single Live Birth", and �Diagnosis, Active: Single Liveborn Newborn Born in Hospital" value sets reference SNOMED only.
o NQF480 �Procedure, Performed: Parenteral Infusion" references SNOMED, ICD-9, and ICD-10
o NQF164 �Procedure, Performed: Hospital Measures-PCI" references SNOMED only
o NQF527 �Procedure, Performed: Hospital measures-Other Cardiac Surgery" references ICD-9 and ICD-10 only.
� Certain CQMs can be calculated only using SNOMED or only using ICD but not the other due to missing entries making it impossible to harmonize data collection, data exchange, and quality measurement on one vocabulary. For example
o NQF436 includes "Diagnosis, Active: Atrial Fibrillation/Flutter" which can be expressed in SNOMED but has no equivalent values in ICD.
o NQF147 includes �Diagnosis, Active: Hospital Measures-Pneumonia" can be expressed using ICD-9 but has no equivalents in SNOMED.
We suggest that the rules, standards, and CQMs need to consistently use vocabulary as follows:
� Accept ICD-9 in lieu of ICD-10 until ICD-10 is introduced.
� Consistently allow for either SNOMED, ICD-9, or ICD-10 for diagnosis and procedures used in data collection, data exchange, and/or clinical quality measures.