Representing Nutrition Assessment, Diagnosis, Interventions and Monitoring/Evaluation

The CPT Category II codes…

The CPT Category II codes are intended to be used in the quality measure sets for which they were developed and not independent of the measure set. The AMA asks ONC to remove the following bullet under “Applicable Value Set(s) and Starter Set(s)”:

• CPT Category II  3759F and 3760F: identify assessment and screening for nutrition within the treatment of another clinical condition

The AMA requests that the…

The AMA requests that the following bullet under “Applicable Value Set(s) and Starter Set(s)” be deleted:  

• CPT Category II  3759F and 3760F: identify assessment and screening for nutrition within the treatment of another clinical condition

  Use of CPT Category II codes are limited to the quality measures for which they were developed.

NCPDP Comments

NCPDP supports ONC’s recommendations.

Preserving Clinical Context

General Comments: USCDI specifies lots of clinical data classes and data elements

• Resolving to myriad de-coupled fragments
• With vanishingly little focus on:
  • Clinical context and vital inter-relationships, e.g., between problems, diagnoses, complaints, symptoms, encounters, allergies, medications, vaccinations, assessments, clinical decisions, orders, results, diagnostic procedures, interventions, observations, treatments/therapies, referrals, consults, protocols, care plans and status...
  • Elements and context + purpose of capture:  e.g., blood pressure, its measurement (systolic, diastolic), its unit of measure (mm/Hg), its reason for capture, its context of capture (sampling site, sampling method, patient position, at rest/during/post exercise...

It is crucial to consider and determine/resolve how clinical content and context are bound together and preserved in USCDI.  The ultimate end user (often a clinician) must be able to readily discern context and inter-relationships – otherwise USCDI places an undue (and often unresolvable) burden on this user.  Only the source EHR/HIT system can structure clinical content and context properly.  Once data is stuffed into the USCDI framework and related exchange artifact (e.g., FHIR resources) this opportunity is forever lost.

The AMA requests that the…

The AMA requests that the Current Procedural Terminology (CPT) code set be added to the standards listed in Section I: Representing Nutrition Assessment, Diagnosis, Interventions and Monitoring/Evaluation. CPT codes 97802 – 97804 identify patient assessment and intervention of medical nutrition therapy. In addition, CPT Category II codes 3759F and 3760F identify assessment and screening for nutrition within the treatment of another clinical condition. CPT is a comprehensive and regularly curated uniform language that accurately describes medical, surgical, and diagnostic services and provides for reliable communication among users. It has an extremely robust and mature development process with open and transparent meetings and clinical input from national medical specialties and relevant stakeholders. It is the most widely adopted outpatient procedure code set. Use of the CPT code set is federally required under HIPAA.