Why the SNOMED-CT Code Framework for MTM Services Is a Big Deal for Pharmacists

As pharmacists look toward initiatives like provider status and clinical services expansion, the question “How am I going to bill for this?” seems to be on everyone’s mind.

This question, while important, isn’t the only thing pharmacist clinicians should be contemplating. In a world where the adage “If you didn’t document it, it didn’t happen” drives all health care professionals’ daily practice, the question “How am I going to document this?” is just as important as the billing one.

On August 23, 2016, pharmacist stakeholder groups released their proposed answer to the documentation question. The Academy of Managed Care Pharmacy (AMCP), Pharmacy Quality Alliance (PQA), and Pharmacy Health Information Technology Collaborative (PHITC) released a draft copy of the “Standardized Framework for Cross-Walking MTM Services to SNOMED CT Codes,” which is available for public comment through September 16, 2016.

What Are SNOMED-CT Codes?

Simply put, they’re standardized clinical terminology used internationally to document data concerning clinical care. SNOMED-CT codes are considered a core component of obtaining interoperability between electronic health records. Outside of informatics circles, however, they haven’t been getting their fair share of press, which is likely due in part to greater attention being given to the controversial conversion from ICD-9 to ICD-10.

Similar to how ICD-10 offers the capability of obtaining greater specificity in coding than ICD-9, SNOMED-CT codes off an incredibly detailed, structured system for documenting the finer details of clinical encounters. I’m not implying this coding set is an updated version of our current diagnostic coding. Rather, it’s my understanding that SNOMED-CT codes are quite different from the ICD coding systems.

So, why should pharmacists pay close attention to SNOMED-CT codes? The answer is simple: because the Centers for Medicare and Medicaid Services (CMS) says so.

The Enhanced MTM Model Test

Beginning January 1, 2017, CMS will be launching an 11-state pilot of the Part D Enhanced MTM Model. According to CMS.gov, this 5-year project is part of a “better care, smarter spending, healthier people” approach to health care delivery that will work to improve the alignment of incentives between government and insurer financial interests, as well as create incentives for Part D plans “for robust investment and innovation in better MTM targeting and interventions.”

What does all that have to do with SNOMED-CT? According to the draft framework, its codes will be used to document interventions conducted in the enhanced MTM pilot. CMS has been pushing the use of SNOMED-CT codes through its meaningful-use initiatives, so it isn’t surprising that the use of this coding framework is extending into pharmacy.

Requested Areas for Comment

The 38-page framework posted for comment on the AMCP website touches upon a wide spectrum of topics integral to how most pharmacist-driven clinical practices conduct their services. The framework poses specific questions related to topics like medication reconciliation, targeted medication reviews, and patient-centered care plans. Overall, the framework is bursting with recommendations that will, in all likelihood, have long-lasting ramifications if adopted.

That said, this topic shouldn’t be left to those more interested in areas pertaining to informatics and technology. On the contrary, it’s important for those who actually spend the majority of their time providing services to patients to review the document and ensure the recommendations it contains align with how their clinical practices are conducted.

Implementation of health informatics has drawn a lot of criticism over the years from physician groups that bemoan the lack of clinician involvement in the development and implementation of mandatory technology requirements. This is the pharmacy profession’s chance to make sure we aren’t left issuing similar complaints.

AMCP, PHITC, and PQA have done their part making sure pharmacy stakeholders are at the table when discussing these important issues, but now it’s up to the larger pharmacist community to do ours. Whether we like it or not, technology and clinical coding are major driving forces in how we deliver care to our patients, so we need to ensure we shape the documentation system to fit our practice. If we don’t, we may be left shaping our practices to meet new documentation requirements.