ICD-10 Code Update
[Update to this Post: In the 2022 ICD-10 code structure, CMS added food insecurity tracking options but delayed a decision the proposed code to indicate when financial constraints prevented patients for following a clinically-indicated dietary regimen. This is an important code because it reflects not only a health-related social need (which we know has long term implications for health) but also that this need is having a direct impact today on treatment for an existing health condition. In the 2023 ICD-10 codes, CMS added this option: Z91.110 “Patient's noncompliance with dietary regimen due to financial hardship”]
On October 1st, the 2022 ICD-10 Code schedule will go into effect - and with the latest update will be additional coding options for food insecurity.
ICD-10 are a set of common diagnosis codes (ICD = International Classification of Disease, 10th edition) managed by the Centers for Medicaid and Medicare Services (CMS). Together with the CPT (Common Procedural Terminology) codes for clinical procedures and services, managed by the American Medical Association, and the HCPCS (Healthcare Common Procedural Coding System) codes, which include and expand on CPT codes, they make up the common lexicon for documenting, and billing for, our health care.
If you think that was a lot of acronyms all at once, just know that it was the pared down version.
The important thing: for a health care provider to both offer a service and get paid for it, they need a way to document what happened in a language that will be recognized by all payers. Common coding that’s followed by payers goes hand-in-hand with common coding recognized across health care records systems, allowing continuity in information as well as care coordination. And there is a dedicated group of very detail-oriented people who keep that all running smoothly.
Here, we’re talking about the diagnosis part of these codes. In 2016, CMS introduced something called the “z-codes” to start including social drivers of health, like food insecurity, in the diagnosis options. On October 1st, CMS will update the specific elements of the food insecurity codes to allow them to be more specific. Here is the 2019 memo from Blue Cross Blue Shield of Vermont, on behalf of a coalition of stakeholders, explaining the requested change and the reasons for it.
Is this arcane? Yes. But it’s also building the scaffolding for fully integrating food as part of health care, including supporting the health care practitioner'’s role in working directly with individual patients on their health concerns, goals, and specific steps to reach good health. The ICD-10 code update is one part of a larger national effort to create the data terminology needed to formally recognize SDOH within health care practice. The collaborative, called The Gravity Project, was founded by the University of California San Francisco Social Interventions Research and Evaluation Network (SIREN). Vermonter Sarah DeSilvey leads the SDOH informatics. This March 2021 Healthcare Innovation article summarizes the work and its implications.
This code change is also one step in building systems to reimburse for food access related services when they are deemed medically necessary. Reimbursement has many, many parts. There’s recognizing a diagnosis and recognizing the appropriate services to go with that diagnosis. Recognition is not synonymous with reimbursement, nor does reimbursement by one type of payer mean that reimbursement happens for all payers . . . or to all health care provider types. Nonetheless, the ICD-10 coding changes that have happened over the past several years are a positive step in the right direction. We can also see where having more information on a patient’s broader health picture adds up indirectly to reimbursement. For example, in 2021 changes to the system for calculating the payment for an office visit allowed providers to use complications related to SDOH as part of calculating the medical decision making level (see article here for details).
These 2022 coding updates go along with many other recent steps forward to solve technical barriers to food access and health care integration. We may soon be at a tipping point where food becomes a fully recognized part of health care in the U.S.