Comment on FR Doc # 2012-04430

Throughout the proposed regulations SNOMED-CT is identified as the preferred diagnostic nomenclature for both tracking and sharing clinical data. However on October 1, 2013 CMS will require reporting all diagnosis codes using ICD-10. First this will lead to expensive duplication. Second this will lead to potentially dangerous confusion. How can one justify reporting a diagnosis of Diabetes using ICD-10 as the patient's primary diagnosis and keeping track in the same chart of an active problem of Diabetes using SNOMED-CT? The codes and concepts are not identical and this will lead to expensive and dangerous duplication of data.