National Center for Health
Statistics
ICD-10 CM Coordination and Maintenance Committee
331
Toledo Road
Hyattsville, MD 20782
nchsicd10CM@cdc.gov
Dear Committee Members:
I am writing on behalf of the 25,
000 members of the Massachusetts Medical Society in strong support of the
Vermont Blue Cross Blue Shield/Yale School of Nursing application for expanded
ICD-10-CM language to create separate codes specific to patient food
insecurity, water security, and related nutritional concepts:
- Z59.41
Lack of adequate food
- Z59.42
Food insecurity
- Z59.43
Lack of safe drinking water
- Z71.85
Counseling for socioeconomic factors
- Z91.110
Patient’s noncompliance with dietary regimen due to financial hardship
The Massachusetts Medical Society has strong policy in support of the screening
for food insecurity and other social determinants of health. The inclusion of ICD 10 codes to record
efficiently the patient’s responses and physicians’ work into an EMR is critical
to making screening for social determinants a fundamental part of the health
care visit.
As physicians, we know that social
determinants of health play a key role in health outcomes and health
disparities, and that addressing the social determinants of health for patients
and communities is critical to the health of our patients, our communities, and
a sustainable, effective health care system.
Our goal is to work with physicians, health systems, and payers to
develop sustainable care delivery and payment models that incorporate
innovative and creative ways of improving the social determinants of health for
all patients. In addition, we are
committed to educating our members about social determinants of health and the
importance of addressing social determinants of health in order to improve
health outcomes and promote health equity.
The
MMS is working closely with a number of our partners in Massachusetts to
address food insecurity and the role of physicians and health care providers. We are a member of the Food Massachusetts Food
is Medicine State Plan, a two-year initiative co-led by CHLPI and Community
Servings, which has been referenced by other commenters. As part of the State
plan process, the MMS convened a physician-specific session organized to
discuss food insecurity. One of the main
issues raised by the physician participants was that the lack of an appropriate ICD-10
code which limited physician’s ability to track food insecurity and integrate
effective treatment plans into patient care. Health care providers also highlighted
associated challenges, such as the inability to obtain reimbursement for
screening and referrals to outside organizations that could significantly
improve the health of their patients.
The Centers for Medicare and Medicaid Services (CMS), the American
Academy of Pediatrics, the American Diabetes Association, the Academy
of Nutrition and Dietetics, and AARP all strongly support screening patients for food insecurity and connecting patients to
food resources. However, few health care systems in the
country have implemented standardized screenings and/or automatic referrals to
appropriate nutrition services. Current lack of specificity in ICD-10-CM
language around food insecurity hampers progress in monitoring risks associated
with food insecurity and limits the ability of health care providers to refer
patients to appropriate nutrition services available in the community.
This code request is built upon
the clear and defined concept of food insecurity and is necessary to better
track and appropriately address the nutrition drivers of morbidity seen in
clinic, hospital, and community settings every day. We therefore urge the ICD-10-Coordination and
Maintenance Committee to accept this careful application.
Sincerely,
Maryanne C. Bombaugh, MD, MSc,
MBA, FACOG
