With less than nine months to go until implementation, uncertainty once again surrounds the ICD-10 program as opponents push for yet another delay in deploying the new code set.
Congress last spring postponed the Oct. 1, 2014, activation date by one year. The original deadline to comply with the system to replace the current ICD-9 coding set was October 2011. That deadline was subsequently extended to 2013, then again to October 2014.
Whether a third delay is in the cards remains to be seen. In December, the nation’s largest state medical society, the Texas Medical Association, urged its 48,000 members to write Congress requesting a two-year deferment.1 The group cited ICD-10’s cost of compliance and the potential for cash flow disruptions, as well as the combined burden of other mandated regulatory programs. The American Medical Association has long opposed the code transition.
Cindy Slocum, McKesson Business Performance Service’s project manager for ICD-10 implementation, said that if another delay is imposed, it would likely follow the pattern established by last year’s interruption. In late March, Congress unexpectedly added language halting the ICD-10 roll-out to legislation designed to prevent Medicare reimbursement cuts mandated by the Sustainable Growth Rate (SGR) payment formula.
Slocum added that while the possibility of another interruption is real, it would be unwise for practices to bank on that prospect. Halting preparations could have serious consequences if the existing deadline remains in place, since groups wouldn’t have time to make up for lost ground.
“I understand that the ambiguity surrounding ICD-10 puts physician groups in a very difficult situation, given the efforts made and money spent last year,” she said. “But as hard as it is, practices must persevere, since the impact of halting preparedness efforts could be disastrous if the October 2015 deadline stands.”
Slocum added that as part of their preparation work, it is imperative that practices assess the readiness of their clinical partners to provide outbound data feeds for demographic and charge information. If hospitals aren’t ready or are slow in establishing the necessary system interfaces, physician practices could take a significant financial hit.
Of particular importance are hospital IT conversions underway or planned for the second half of 2015. Without ample lead time, she said, it will be difficult for any billing entity to complete the necessary interfaces and ensure uninterrupted data feeds.
To head off these problems, Slocum said practices that bill in-house as well as those that outsource should reach out to their hospitals to learn more about the facility’s ICD-10 plans. In the case of McKesson clients, groups should also work to facilitate direct communication between the hospital and the McKesson client manager.
Proponents of the existing 2015 compliance deadline, including the American Health Information Management Association, say that another delay would be costly and destructive to healthcare reform efforts.
“There is no benefit to continuing to use an outdated coding system that is not current with today’s clinical practices,” said Sue Bowman, AHIMA’s senior director of Coding Policy and Compliance, in a recent Q&A with hittechanswers.net. “We would lose a lot of ground as an industry in moving toward better decision-making based on data.”2
Bowman added that stakeholders who have already invested significant resources in training and workflow changes “will find themselves at a standstill, or burning money maintaining dual coding systems. The last two delays have already generated tremendous, wasteful costs – literally billions of dollars – and we really can’t afford another.”3
Delaying implementation could also impact efforts to control waste and fraud, since ICD-9 codes are inferior in their ability to reveal improper and inappropriate coding and claims, according to Carl Natale, editor of ICD10Watch.4
Another expert, Stanley Nachimson, told Government Health IT in November that whether the rollout will be delayed or not will turn on how much progress the industry makes toward compliance over the next six months.
“If CMS can report to the industry and Congress that providers, plans and vendors have made progress and are moving toward the October date, then there will be no reason for a delay,” he told the publication. “If there is little progress, then I think either CMS or the Congress may step in.”5
Given the delays that have already beset the ICD-10 implementation, some observers have suggested that it might make sense to bypass ICD-10 and move directly to the next code iteration, ICD-11. ICD-11 is scheduled to be implemented in most other developed nations starting in 2017.
That option, however, is not realistic, according to the Coalition for ICD-10, an advocacy group that supports implementing ICD-10 within the existing timeline.
“ICD-11 is built on ICD-10 and benefits from the clinical knowledge and additional detail that have been incorporated into the U.S. version of ICD-10,” the organization wrote in a recent commentary on the issue. The group went on to note that even the AMA’s board of trustees — opponents of the existing ICD-10 timeline — recommended against moving straight to ICD-11, calling the idea “fraught with pitfalls.”6
In December 2013, McKesson began shifting coders to the new code set via an in-house application that automatically converts ICD-10 codes to ICD-9 for claims submission. The software, coupled with extensive training, has allowed the company to get a running start at complying with the new coding requirements. ICD-10 increases the number of diagnosis codes from about 14,000 to approximately 69,000 and boosts the number of procedure codes from 3,000 to roughly 87,000.
So far, about 375 coders working in a variety of medical specialties have collectively processed about five million patient encounters in ICD-10, according to Slocum. The balance of McKesson coders should complete the transition to ICD-10 by June 2015.
The early adoption program has helped identify reoccurring problems in the physician documentation required to support ICD-10 coding. Slocum said the company is working with clients to mitigate the errors. She said the bulk of these mistakes fall into eight general areas:
“There is no question that the accuracy of clinical documentation will have an enormous impact on how the ICD-10 transition unfolds,” Slocum said. “It is therefore critical that physicians and practices use the time remaining to develop and hone their documentation skills.”
1Joseph Conn, “Texas doctors beat drum for longer ICD-10 delay,” Modern Healthcare, Dec. 3, 2014, http://www.modernhealthcare.com/article/20141203/NEWS/312039927
2“AMA Pushes Again for ICD-10 Delay,” Hitech Answers, Dec. 8, 2014, http://www.hitechanswers.net/ama-pushes-icd-10-delay/
4Anthony Brino, “ICD-10: Ready to waste more money?,” Government Health IT, Nov. 13, 2014, http://www.govhealthit.com/blog/icd-10-ready-waste-more-money
6“Commentary: Waiting for ICD-11,” Coalition for ICD-10, Jan. 13, 2015, http://coalitionforicd10.org/2015/01/13/waiting-for-icd11/