Better integration of pharmacists into the Medicare Part D MTM program is one of the objectives of the CMS Medicare and Medicaid Innovation’s (CMMI) Part D Enhanced Medication Therapy Management Model. This new model is designed to test whether high quality, “enhanced’ medication management can save money and improve the quality of health for seniors and the Centers for Medicare and Medicaid Services (CMS) has developed new MTM related data and metric collection requirements for monitoring and evaluation purposes.
In a previous blog post “Enhanced MTM Model: Monitoring Success” I mentioned that this monitoring and evaluation will be done using SNOMED codes. I had heard of SNOMED codes being used by Kaiser Permanente and Veterans Health Administration to link clinical terms to codes, so when it was announced that CMS was planning to use SNOMED codes in their Enhanced MTM model, I started doing some more research and here is what I found:
SNOMED CT (Systematized Nomenclature of Medicine Clinical Terms) codes are a list of value sets owned and distributed by the International Health Terminology Standards Development Organization (IHTSDO). SNOMED CT codes can be used to represent clinically relevant information consistently and reliably. The hundreds of thousands of SNOMED CT codes provide a standardized way to represent clinical phrases captured by the clinician and enables automatic interpretation of these.
On November 18, 2015, CMMI identified the use of SNOMED CT code collection as a means to standardize the data and as a method to detail MTM-related activities and outcomes in the Enhanced MTM Model. CMS will not be identifying specific codes but is asking prescription drug plans to be innovative and find out which outcomes really make a difference to patient care.
Of the hundreds of thousands of SNOMED CT codes in the international database, the Pharmacy Health Information Technology Collaborative has identified about 300 terms that can currently be used to document MTM services. The founding members of the Pharmacy HIT Collaborative include APhA, ASHP, ASCP, NCPA, NASPA, ACPE, ACCP, AACP and AMCP. The Pharmacy HIT Collaborative, founded in 2002 to improve the coding infrastructure necessary to support billing for pharmacists’ professional services, has a work group dedicated to professional service documentation and coding, with a focus on SNOMED CT codes.
Enhanced MTM Model plan sponsors have two options for situations in which they cannot identify a SNOMED CT code in the enhanced MTM value sets:
- Search the SNOMED CT database of codes, and identify and use a SNOMED CT code that is not included in the enhanced MTM value set or
- If a suitable code cannot be found after a reasonable search, plan sponsors should enter the code ZZZZZ in the Encounter Code field and a text description of the activity in the Encounter Code Description field.
To request that a new SNOMED CT code be created, sponsors should complete the appropriate form on the Pharmacy HIT Collaborative’s website (http://www.pharmacyhit.org/).
According to the Enhanced MTM Encounter Data Specification Plan , CMS will be offering trainings to participating plan sponsors and MTM providers on the proper coding and will provide an Enhanced MTM Encounter Data Companion Guide.
The cost for implementing the SNOMED CT codes in an organization’s current Electronic Health Records (EHR) or Health Information Technology (HIT) systems is unknown. If an EHR compendium vendor or MTM subcontractor is used by the plan sponsor, the process of entering codes into the system may be done automatically through the vendor. No additional licensing needs to be purchased to use SNOMED CT.
CMS believes this is the best choice for pharmacists to electronically capture pharmacist-provided patient-care outcomes because all systems will use the same codes. Pharmacists will have the ability to document their actions, track outcomes and prove the value of pharmacist-provided MTM services. The question that comes to mind is will the use SNOMED CT codes by pharmacies become as common as using NDC numbers? Want to learn more? Go to the Value Pharmacists Online Resources Page and click on Pharmacy HIT Collaborative and check out the SNOMED CT Implementation: A Beginner’s Guide .
Let’s talk. Contact me at val@valuepharmacists.com or comment below!